HOEPA
The Homeownership and Equity Protection Act (“HOEPA”) is implemented by Section 1026.32 of Regulation Z. Changes to the regulation which carry a mandatory effective date of October 1, 2002 bring many more loans within the purview of these “high rate” mortgage provisions. All lenders should perform an analysis of their consumer mortgage loans to determine if any will now be covered by HOEPA, keeping in mind that the smaller the dollar amount, the shorter the term, the greater the likelihood that a loan could be covered. One of the big changes is that credit life insurance premiums are now included in the “fees” for purposes of determining whether the fees on the loan exceed the threshold dollar amount. Below, you will find several resources which will aid you in understanding the changes and the requirements.
***HOEPA SPREADSHEET CALCULATION TOOL ONLY VALID FOR LOANS CLOSED PRIOR TO 01/10/14***
Links
Plain English summary from one of the Gurus at Bankersonline
Federal Reserve Board Press Release (with attached Final Rule) about the HOEPA changes
Reg Z – Section 1026.32
OCC APR Calculator
Documents
HOEPA Spreadsheet – A user friendly excel spreadsheet is available. Input the requested information and the program will tell you whether your loan is subject to HOEPA.
Article 9 Perfection Chart
Maximum Annual Percentage Rate Chart and Pricing Matrix for Loans under U3C 3-508-A – effective July 1, 2014
Maximum Annual Percentage Rate Chart and Pricing Matrix for Loans under U3C 3-508-A – effective August 22, 2014
Limitations on Terms of Consumer Credit Extended to Service Members and Dependents
July 2015 3-508A – Split Rates (PDF)
July 2015 3-508B Loan Pricing Matrix (PDF)
3-508-B Calculator
[Click here] to access the 3-508-B Loan Pricing Calculator.
