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#1985788 - 12/31/14 03:47 PM HOEPA test
Tesla Offline
Power Poster
Joined: Nov 2003
Posts: 3,726
I have thoroughly confused myself. For 2015, when you look for the APOR to compare your loan to, are you still using the 15th of the month prior to the application date or has that changed?
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HOEPA and Homeowner Counseling Rule
#1985931 - 12/31/14 09:43 PM Re: HOEPA test Tesla
Diane Dean Offline
Member
Joined: Oct 2012
Posts: 92
You would use the APOR from the date you set the interest rate for your transaction.

"High-cost mortgages include closed- and open-end consumer credit transactions secured by the consumer's principal dwelling with an annual percentage rate that exceeds the average prime offer rate for a comparable transaction as of the date the interest rate is set by the specified amount..."
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