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

HOEPA does apply to refinancings with no new money. It sounds like you do not need a RofR.

Thanks, That's what I was thinking.

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

Bump Bump

If it's a true renewal and not a refinance, no disclosures are triggered.