Calculation of Fees Subject to HOEPA
Answer by Dan Persfull, BOL Guru Guru Bios
Question: In the calculation of fees subject to HOEPA on covered loans, do you include the entire mortgage insurance premium or only the amount paid at closing?
Answer: You will find your answer in Regulation Z where the specifics of what is included in the HOEPA calculations are described. See 226.32(a)(1)(ii).
Editor's Note: You may also find this HOEPA Worksheet tool helpful and it also specifically addresses the question. In PMI, the initial deposit is included.
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