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#1082124 - 11/14/08 05:38 PM HOEPA??
dblack Offline
Gold Star
Joined: Feb 2008
Posts: 263
AL
We have an in-house renewal of a customers primary residence with no new money being advanced.

So the standard ROR would not apply being that we are not issuing new money.

However, the loan falls within the rate spread test for HOEPA.

Do we need the HOEPA ROR??

Thanks
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Lending Compliance
#1082141 - 11/14/08 05:56 PM Re: HOEPA?? dblack
David Dickinson Offline
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David Dickinson
Joined: Nov 2000
Posts: 18,762
Central City, NE
HOEPA does apply to refinancings with no new money. It sounds like you do not need a RofR.
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#1082181 - 11/14/08 06:27 PM Re: HOEPA?? David Dickinson
dblack Offline
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Joined: Feb 2008
Posts: 263
AL
Thanks, That's what I was thinking.
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#1105853 - 01/06/09 02:54 PM Re: HOEPA?? dblack
beegee Offline
Diamond Poster
Joined: Feb 2004
Posts: 1,099
South
I have a follow-up question on this:

Is HOEPA applicable to "renewals" where we are basically just "modifying" the original note?

My understanding is that if we are "refinancing" with a new note then HOEPA would apply. Is my understanding correct on this?


Thanks,
beegee

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#1106639 - 01/07/09 03:06 PM Re: HOEPA?? beegee
beegee Offline
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Joined: Feb 2004
Posts: 1,099
South
Bump Bump

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#1107623 - 01/08/09 05:29 PM Re: HOEPA?? beegee
David Dickinson Offline
10K Club
David Dickinson
Joined: Nov 2000
Posts: 18,762
Central City, NE
If it's a true renewal and not a refinance, no disclosures are triggered.
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