bump
It may be a really dumb question, but if anyone would be able to contribute as to how they are implementing this change I would greatly appreciate it.
My understanding is that with all of the Reg Z changes in the past, we just go in and update the value in the field so that the first time it's utilized in the new year the new amount will be applied/relied upon.
But since the January changes specifically said that HOEPA points and fees were effective with applications dated after the 1/10 effective date, I wanted to make sure we applied this first annual increase correctly.