Why Does Real Estate/HE Fall Into HOEPA?

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Question:

What makes a real estate or home equity loan fall into a HOEPA reg?

Answer:

The answer is best found by reviewing the language of Regulation Z's sections 1026.32(a) and (b). In general, a loan subject to HOEPA is a closed-end mortgage loan with a higher APR and/or total points and fees that exceed stated thresholds. Be sure to look at the Official Commentary to sections 1026.3(a) and (b) to get the full answer.

First published on BankersOnline.com 3/18/13