12/09/2013
Beginning in January 2014 we will need to check our HELOC loans for HOEPA coverage. We use the one year treasury as an index (currently .125%) with a 2.75% margin, floor of 5% & ceiling of 12%. The rate is subject to change monthly. It is my understanding that I will add my index to the margin to determine that APR for HOEPA test purposes. I am thinking I would use the floor because that is higher than the index + margin. I do not see that there is an APOR for 1 month, the shortest duration I see is one yr. Any thoughts on what APOR I would use. Does it matter what the ceiling is for the HOEPA test?
06/24/2013
We are making a loan in the amount of $4500 for one year against the borrowers primary residence for the purpose of paying delinquent real estate taxes. The rate will be 7.50% and total fees will be less than $528. The loan is not an HPML, but what about HOEPA? The APR will be over the 8.00% plus treasury but my fees will be less than $528.00. Is there any threshold for a loan amount to be exempt from HOEPA. Please advise.
03/18/2013
What makes a real estate or home equity loan fall into a HOEPA reg?
02/25/2013
Does HOEPA apply to a fixed rate loan secured by a manufactured home and no real estate?
08/29/2011
We have a HELOC open end that matured last month. The loan officer wants to set this up as a 30-year ARM with a 1-year maturity. What documents must we have? Does RESPA apply?
07/25/2011
We have an owner who will not be signing the note and just the mortgage. Should they sign the TIL along with the Right of Rescission?
07/18/2011
A Loan term is for 35 months. On the HOEPA Worksheet, do I select the two year Treasury Security Term or the three year?
06/13/2011
Reg Z - I have a borrower who is using his mother's primary residence as collateral for consumer purpose. The mother is not going to be on the note itself. She is just pledging the collateral. Would the Higher Price Mortgage requirements apply and is an Escrow required?
04/25/2011
Do you file a HOEPA Rider with the mortgage?
04/25/2011
Our Lending area performs an APR test for the purposes of borrower interest underwriting. When testing an APR by using an APR from the TIL, should the APR come from the initial or early TIL or from the Final TIL? We have heard that use of the APR should reflect when the loan is consummated.