I heard that even the HOEPA indicator will be changed under the new HMDA filing rules effective in 2018. Is that true?
We are making a 1st deed of trust loan to purchase a primary residence and a second deed of trust loan for renovations on a 12 month interest only loan (to be refinanced on permanent financing with same lender at maturity by adding 1st & 2nd together). Does RESPA & REG Z both apply...and if so, can you make a 12 month interest only loan if it is a HOEPA loan?
I have noticed that the Rate Yield Table on the FFIEC website has not been updated since 9/15/11. This is where we get the table from for HOEPA loan calculations. Do you know if it has been moved or changed?
Which forms are required to be redone with a rate change? There was not a rate lock; however, the rate went down before closing. If the rate changes before closing, is another HOEPA form required?
We have an owner who will not be signing the note and just the mortgage. Should they sign the TIL along with the Right of Rescission?
Reg Z - I have a borrower who is using his mother's primary residence as collateral for consumer purpose. The mother is not going to be on the note itself. She is just pledging the collateral. Would the Higher Price Mortgage requirements apply and is an Escrow required?
I have a home improvement loan, which I am securing with a title lien on the vehicle. Do HMDA and HOEPA apply?
We have a borrower who has in recent months divorced from his wife, and had deeded the property entirely to her several months ago. The deed was originally in both names and the mortgage was therefore signed by both borrowers, but the husband was the only borrower on the note. At this point the wife would like to assume the note, as she's been making the mortgage payments herself since long before the property was transferred solely into her name. Neither borrower qualifies for a regular refinance, so an assumption seems to be the only way out of the note for the husband. What disclosures need we present to the wife along with the assumption agreement in order to complete this transaction? Do ROR, TIL, RESPA, and HOEPA apply?
Is there a Reg that states that any loan $50,000 or less is exempt from a HOEPA calculation?
Could you please tell me what the HOEPA 2010 Annual threshold figure is?