I am looking for verificiation regarding HOEPA and Balloon payments. At a recent training seminar, we were told that HOEPA loans must have a minimum term of 5 years. We have scoured the regs for a definitive answer and cannot find any such documentation. Is there a minimum period for balloon payments on HOEPA loans?
How long from the time of application does the Bank have to provide HOEPA disclosures on a HOEPA loan request?
When disclosing a HOEPA loan we are required to provide borrower with HOEPA disclosures 3 days prior to closing the loan. If the loan has a 3 day right of recission, are we in compliance by disclosing at the time the loan is closed if funding of loan is not until 3 days?
The proposal, following on the advance notice of proposed rulemaking, is now out. It may look innocuous - at first glance. But look again, carefully.
For HOEPA loans, does Saturday count as one of the three days between disclosure and closing?
The FRB has announced its annual readjustment of the HOEPA fee-based trigger for high cost mortgage calculations. The figure for 2004 will be $499.
Question: We are hearing confusing things about high cost mortgages and changes to the triggers.
Is the HOEPA disclosure necessary for each and every closedend home equity loan or only the loans that meet the outlined criteria? Perhaps a better question would be this: do specific outlined criteria exist such that all the types of nonHELOC loans would ultimately fall under HOEPA?
This is in reference to Reg C and HOEPA. Our program that we use for closed end consumer credit has only 1 spot to input the treasury maturity. Are we okay using the 10 year maturity only?
What is HOEPA?