Well, I, for one, did not have a day off yesterday. So my cruising was completely normal and within the bounds of my job responsibilities.

Dan, while I agree that there should be some allowance to be able to accomodate customers (especially high net worth and knowledgeable customers), FRB was up against the blocks. Because some few unscrupulous lenders didn't have a problem with sticking balloon loans to less knowledgeable customers, they had to put a rule in that in effect disallowed any type of balloon option, including single-payment, for high-cost consumer purpose principal-dwelling secured mortgages. There is not any way that they could have written the regulation to allow these for knowledgeable borrowers without opening up the window again for the unscrupulous of our number to jack it to the less knowledgeable.

I also had to work yesterday.

Jim, you and Randy have convinced me that HOEPA sucks.

I just did a quick calculation on a $50,000 6 month construction loan, which is how we would set up this scenario, at 7.5% interest rate, a $7.00 LOL fee, and 1% origination fee and no other charges. The APR caculated at 11.853%. Based on the 1 yr treasury yield for 10/15, the max APR is 11.790%. The total cost for the $50,000 was about $949. To me this is not a high cost loan, but due to the consruction monitoring it would be a high maintenance loan, all well go figure.

Again, I'm glad we price our loans as we do.

Sorry Mary, I humbly relinquish my cape.

No problem Dan, I'm sure you'll earn it back!

I'm thinking that prime +1 might get us under the HOEPA bar. Selling that to management will be like John Denver opening for Mega Death though.

Since you're halfway across the country, and out of my market area, can you share your pricing strategy?

(Tongue firmly planted in cheek.) The point is moot if the lender gets a combined waiver for RoR, flood and HOEPA at closing... or documents it afterwards.

What keeps us out of HOEPA is we charge no origination fees nor do we sell credit insurance on these products.

Our secondary market loans are priced based on market rates just as anyone else's. Our in-house loans are ARMs and they are priced at Prime plus 1 or 2 with a floor of 7 or 8.

You mean my lenders can't waive it on their own?

Oh, darn, and here all this time I thought they were Congress!!