The Federal Reserve has published its annual adjustment to the HOEPA trigger fee, the dollar amount that should be used in high-cost loan calculations.
Can you explain why MOB (monthly outstanding balance) credit life/A and H insurance is not used in the calculation of the HOEPA fee trigger?
What is the HOEPA reporting threshold? Is there something that relates to loans under $50,000? If so, where would I find this guideline?
Is there software available to help me calculate the APR, ROR accuracy, high cost loans, and individual state compliance, i.e. Texas and compliance issues in general.
Following the old advice of something old, something new, the OCC has issued guidelines on establishing standards for national banks on mortgage lending.
The final lap of the new 2004 HMDA reporting is now being run.
FRB rep clears up Reg C's gray areas
by Mary Beth Guard, BOL Guru
Our bank offers real estate loans as 3 year and 5 year balloons based on 15 year ammortizations and 15 year fixed rate loans. For HOEPA purposes should we use the 3 year and 5 year Treasury rates for the balloon notes or is the 10 year Treasury rate OK for all instances since the balloon notes are usually 15 year ammortizations?
What are some examples of section 32 applicable fees?