If an individual uses his personal residence as collateral for the purchase of a rental home, is this a business purpose under HMDA? If not, how do I show his approved application (loan not closed/funded) on the LAR?
A customer wants a loan to refinance his home and get money to improve it. The loan will be for six months, with interest only payments while the work is completed. At the expiration of six months, the loan will be modified to be a seven year balloon loan. At inception, isn't this loan HMDA reportable and HOEPA applicable?
I need clarification on balloon payments. Are we not allowed to have balloon payments on any loan or does it just apply to HOEPA, high rate high fee loans?
Am I correct in understanding that with a variable rate real estate loan subject to the higher priced mortgage loans effective 10/01/09 under 226.32(b)iv, the initial rate cannot change until after four years?
Is there a HOEPA worksheet available that is for loans after 10/1/09? My understanding is that if the APR on a first lien principal dwelling loan exceeds the average prime rate offer by 1.50%, the loan is considered a HOEPA loan.
Does the point and fee test still apply for the HOEPA test or does the Reg C amendment only call for APR test?
How can a HOEPA violation be fixed? Would refunding charges and rewriting the loan under section 32 regulations be acceptable?
Does HOEPA Chapter 49 Section 4903 pertain to PMI upfront disclosure or should I be looking in the Homeowners Protection Act? Where is that regulation?
I am trying to find what the HOEPA threshold is for 2008. Can someone tell me where I can find what it is?
We have a question concerning HOEPA. On the <a href="http://www.bankersonline.com/tools/lender/hoepa.html">worksheet</a>, it says fees for charges paid by the consumer at or before closing. Is that fees for the service or the actual charge? We are not sure.