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#1770351 - 12/26/12 05:10 PM New HOEPA Worksheet
SMQ, CRCM Offline
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SMQ, CRCM
Joined: Apr 2001
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I think I know the answer, but I have talked myself in circles today. We use the updated HOEPA worksheet to test our loans, thank you Compliance Consulting, http://www.bankersonline.com/tools/hoepa2013-1.xls

What triggers the use of the new worksheet with the new exemption amount? Do we use this one for applications taken after Jan 1, or for loans that close after Jan 1?

Thanks,
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Lending Compliance
#1770528 - 12/26/12 10:18 PM Re: New HOEPA Worksheet SMQ, CRCM
Diane Dean Offline
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Joined: Oct 2012
Posts: 92
You will want to use the adjusted dollar amount for 2013 for loans originated in 2013. Please note the other criteria that can trigger "HOEPA status" is based on Treasury Securities and the timing of the application. Hopefully this helps!
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Diane Dean
http://www.bankerscompliance.com

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#1770530 - 12/26/12 10:23 PM Re: New HOEPA Worksheet SMQ, CRCM
SMQ, CRCM Offline
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SMQ, CRCM
Joined: Apr 2001
Posts: 4,828
Between the lines
Thanks Diane Dean, I got all that. The question (poorly asked on my part) is in regard to the new adjusted dollar amount, as in 2013 worksheet. Use this worksheet for loans that are APPLIED FOR after 1-1 OR use it for loans that actually CLOSE after 1-1 (even though they were applied for in 2012)?

Some refer to originated as the date of application, others say originated is the date the loan is signed/closes.
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#1770534 - 12/26/12 10:32 PM Re: New HOEPA Worksheet SMQ, CRCM
Diane Dean Offline
Member
Joined: Oct 2012
Posts: 92
You will want to use the 2013 worksheet for loans that close in 2013.
_________________________
Diane Dean
http://www.bankerscompliance.com

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