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#1890405 - 01/24/14 10:39 PM Re: Confusion - High Cost - HOEPA & High priced Squeakers
dblack Offline
Gold Star
Joined: Feb 2008
Posts: 263
AL
I know what you mean. When you think you have this stuff figured out, a small detail will trip you up every time.
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HOEPA and Homeowner Counseling Rule
#1890411 - 01/24/14 10:44 PM Re: Confusion - High Cost - HOEPA & High priced Squeakers
Red Raiders Offline
Diamond Poster
Red Raiders
Joined: May 2013
Posts: 1,055
Compliance Land
I thought I had a good handle on the changes until little things that come up that make me read closer. Glad I'm not the only one!
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#1890520 - 01/27/14 03:10 PM Re: Confusion - High Cost - HOEPA & High priced Red Raiders
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 39,697
Cape Cod
Originally Posted By: raidersn2000


My head is spinning more than that girl from The Exorcist!!


Trivia: Do you remember the little girl's name, and who played her in the movie?

Regan; Linda Blair. And it's killing me to realize she's 55 now!
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#1891009 - 01/28/14 02:19 PM Re: Confusion - High Cost - HOEPA & High priced Red Raiders
trout22 Offline
Gold Star
Joined: Nov 2004
Posts: 313
Originally Posted By: raidersn2000
I thought I had a good handle on the changes until little things that come up that make me read closer. Glad I'm not the only one!


It would have been helpful if CFPB would have thrown in the word "MAY" somehow... as in "The HOEPA APR may differ from the TILA APR". Several resources were using language that seemed to indicate that it would ALWAYS vary, but in reality on fixed-rate loans it is the same. I appreciate that they were trying to give us a heads-up, but until you read more closely, it was a bit confusing.

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#1897601 - 02/14/14 10:05 PM Re: Confusion - High Cost - HOEPA & High priced Squeakers
compliancemap Offline
Member
Joined: Apr 2012
Posts: 59
Just to clarify, it does work to use the FFIEC Rate Spread Calculator to complete the APR test for HOEPA loans with apps on or after 1/10/2014, correct? It is confusing since the website says that it should not be used for HOEPA in bold letters on the page where you do the APOR spread calculation. Am I missing something?

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#1897615 - 02/14/14 10:41 PM Re: Confusion - High Cost - HOEPA & High priced Squeakers
dblack Offline
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Joined: Feb 2008
Posts: 263
AL
You use the FFIEC calculator to get your spread over APOR for that portion of the HCML test.
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#1898186 - 02/19/14 05:28 PM Re: Confusion - High Cost - HOEPA & High priced Squeakers
compliancemap Offline
Member
Joined: Apr 2012
Posts: 59
Thanks dblack!

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