Skip to content
BOL Conferences
Thread Options
#1300726 - 12/08/09 03:18 PM HOEPA calculation
HR Banker Offline
Diamond Poster
Joined: Oct 2002
Posts: 1,027
If credit life insurance is purchased but not financed in the loan (poc) does that keep it from being used in the HOEPA calculation? If it had been financed it would have caused the points and fees to exceed 8% of the amount financed and therefore be a HOEPA loan. But, since the insurance wasn't financed we don't have to use that amount in our calculation, right?

Return to Top
Lending Compliance
#1300809 - 12/08/09 04:13 PM Re: HOEPA calculation HR Banker
rlcarey Online
10K Club
rlcarey
Joined: Jul 2001
Posts: 83,227
Galveston, TX
Regardless of how it was paid, it was written in connection with the credit transaction and has to be included.
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

Return to Top
#1300847 - 12/08/09 04:35 PM Re: HOEPA calculation rlcarey
Dan Persfull Offline
10K Club
Dan Persfull
Joined: Aug 2002
Posts: 47,517
Bloomington, IN
Randy's comment is supported by 226.32:

(ii) The total points and fees payable by the consumer at or before loan closing . . .
_________________________
The opinions expressed are mine and they are not to be taken as legal advice.

Return to Top

Moderator:  Andy_Z