HOEPA - Combined Transaction Loan

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Question:

Would a combined transaction loan for the purchase and improvement of a primary residence fall under HOEPA? All loan proceeds will be funded at closing.

Answer:

If you are not taking the existing primary residence as security, and you are closing the loan as one transaction then it would be a residential mortgage transaction and exempt from HOEPA.

First published on BankersOnline.com 10/27/08