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#1661069 - 02/06/12 06:07 PM "High-cost mortgage"
Avanti Offline
100 Club
Joined: Feb 2010
Posts: 139
I have had this question come up and am wondering how others are handling it. We are contemplating a loan program that would qualify as "High-Cost Mortgage" based on the APR charged to compensate for the associated risks.

I am not finding where "High-Cost Mortgage"s have been regulated yet. Are you following the guidelines enacted by Dodd-Frank for high-cost mortgages - such as only two times the amount of regular payment is allowed as a balloon payment (ETA: mandatory loan counseling) - or are you waiting for guidance.
Last edited by Avanti; 02/06/12 06:08 PM.
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Lending Compliance
#1661073 - 02/06/12 06:14 PM Re: "High-cost mortgage" Avanti
C0mpl1anc3 Offline
New Poster
Joined: Jul 2005
Posts: 13
Muncie, Indiana
We are waiting for the final rule. According to a CFPB Agency Rule List, they will be issuing a proposal for changes to Reg Z in July 2012.

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#1661078 - 02/06/12 06:19 PM Re: "High-cost mortgage" Avanti
Avanti Offline
100 Club
Joined: Feb 2010
Posts: 139
So you are holding off on any program that would qualify as a "High-Cost Mortgage"?

Is anyone doing 2-Step Construction lending? We are showing that the APR for the construction phase would qualify as a High-Cost mortgage, and after contacting the CFPB construction loans are no longer exempt.

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