Can someone refresh my memory please? I read this article last week in the banking journal and could not recall the connection between HOEPA and being located in a rural area. We are a small creditor under the ATR rules and are exempt from the second appraisal requirement for HPMLs, but I can't really think of a perk with respect to HOEPA. We don't make loans subject to HOEPA; at the same time, I don't want to miss something!


The Consumer Financial Protection Bureau today released the lists of rural counties and rural or underserved counties that entities can use in 2018 to determine whether they are exempt from certain regulatory requirements under the bureau’s Ability-to-Repay, escrow, HOEPA and appraisal rules. Lists are available for download as Excel, CSV or PDF files. In addition to the lists, the CFPB also provided a tool that can help bankers determine whether a property is located in a rural or underserved area.

I believe it's the ability to make a balloon payment on a HOEPA loan.