We are still struggling with HOEPA. None of us wants to originate HOEPA loans but if we do, we have the disclosures ready to issue the borrower (3 days prior). Is anyone aware of how many or what percentage of a bank's portfolio can be identified as HOEPA loans before the bank is viewed unfavorably by the regulators and/or Community Groups? Has a benchmark been published or discussed somewhere? Any ideas?
There seems to be some confusion regarding the new TIL for High Cost Mtges that go in effect in Oct. Is this new ruling geared towards Primary residents only, or does include investment properties and if so, where can I find the verbage that states just that. I am in the state of Florida.
We understand if we have a Real Estate Loan which falls under HOEPA, we are required to give disclosures 3 days prior to closing. We also give the customer the initial disclosures required by RESPA within three days after receiving their application. If the disclosures we give under RESPA are identical to what HOEPA requires and these disclosures, (for example), are given two weeks prior to closing, would the RESPA Disclosures fulfill the HOEPA disclosure requirements?