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?
Question: We are hearing confusing things about high cost mortgages and changes to the triggers.
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.
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?