HOEPA - Consumer Price Index
Answer by Randy Carey, BOL Guru Guru Bio
Question: What is the Consumer Price Index? Doesn't it vary by state? Where can I get that Index? Do you subtract that from the total fees?
Answer: The Federal Reserve Board uses the Consumer Price Index (it is a national index compiled by the Bureau of Labor Statistics) to determine the limit of total fees and points payable by the consumer at or before closing, before the loan would be considered covered under HOEPA. The total fees and points must exceed the larger of $583 or eight percent of the total loan amount. (The $583 figure is for 2009. This amount is adjusted annually by the Federal Reserve Board, based on changes in the Consumer Price Index (CPI).) The Federal Reserve Board usually announces the new figure for the following calendar year in August or September. The 2010 figure was published in the Federal Register August 12, 2009 and that figure will be $579, as the CPI declined in the most recent measurement period.
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