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HOEPA Worksheets

At this point, Banker's Compliance Consulting, who has maintained this tool, is not planning to update the HOEPA Worksheet for the January 2014 rules change regarding High Cost Mortgages (previously HOEPA loans). There are a couple of reasons behind this decision. First, the "APR test" will be able to be completed on the FFIEC's rate spread calculator. Second, the "points and fees test" requirements are much more individualized and include many more ifs, ands, and buts than before. Thus, to create a "one-size-fits-all" calculator would be quite difficult.

In discussions with bankers they heard of a couple software providers who are adding a "points and fees" calculation tool. This would be a better option for most banks as they could hard code their fees for the calculator rather than trying to utilize a generic calculator. Banks are encouraged to check with their software providers and request such a calculator.

Louvera Walden started this HOEPA Worksheet and handed it off to David Dickinson of Bankers Compliance Consulting. David enhanced the HOEPA Worksheet and Andy Zavoina tweaked it to produce the HOEPA disclosure automatically. Bankers Compliance Consulting is now updating this on an annual basis.

Please note: Doc Prep Fees are only finance charges under Reg Z if retained by the lender, and some states won't allow anyone who is not an attorney to charge them. Even doc prep fees charged by an attorney, however, must be added into the fees and charges calculations in Georgia if the customer did not sign an affidavit of attorney selection. Customize, as needed, for your institution.

Pub. 12/12/13

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