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#33492 - 09/19/02 03:50 PM HOEPA
Anonymous
Unregistered

We really appreciate the HOEPA Worksheet. It's probably as plain as the nose on our face, but what does AFR LOL stand for? Also, do you have to include the Life of Loan Flood Charges for HOEPA?

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Lending Compliance
#33493 - 09/19/02 03:56 PM Re: HOEPA
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 79,234
Galveston, TX
I think that AFR just happened to be the flood determination company used by the developer and the answer to your second question is Yes.
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#33494 - 09/19/02 03:59 PM Re: HOEPA
Miss Kitty Offline
Platinum Poster
Joined: Mar 2002
Posts: 721
California
This raises another question... For loans that are "No point-No fee" (the bank absorbes all fees), are we required to insert POC fees completing the worksheet for all H/E, Refi loans? My thoughts are it does not apply therefore negating the requirement.

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#33495 - 09/19/02 06:16 PM Re: HOEPA
OnTheEdge Offline
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Joined: Apr 2002
Posts: 1,677
SmallTown, USA
I wouldn't think so.........
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#33496 - 09/20/02 10:13 PM Re: HOEPA
David Dickinson Offline
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David Dickinson
Joined: Nov 2000
Posts: 18,762
Central City, NE
No. The "AFR" stands for American Flood Research. This is evidently the company that Louvera Walden's bank uses to complete their flood determinations (she is the designer of the HOEPA worksheet that you downloaded from BOL. BTW, AFR is a great company. We have revise Louvera's original worksheet quite a bit. You can download it at our web page.
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#33497 - 09/20/02 10:31 PM Re: HOEPA
complyguy Offline
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complyguy
Joined: May 2001
Posts: 494
PA
David - our lenders really like the bright colors. They're easily amused. Seriously, the links eliminate one or two manual steps for them, which is good, because they're also easily confused by anything that is different from the way it's always been. Sorry, it's Friday night (we work until 8:00), and my veneer of civility has worn through.

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#33498 - 09/24/02 03:18 PM Re: HOEPA
Anonymous
Unregistered

Okay, I plugged some figures into the worksheet and now I'm really confused. In the loan I am checking, Doc Prep is $150. In house appraisal is $100. Credit Life premium is $2,300. (Yes I know that's high). The Loan amount is $53,000. The worksheet tells me that HOEPA does not apply. I thought that if the total points and fees payable by the consumer at or before loan closing exceed the greater of 8 percent of the total loan amount or $480 then HOEPA applied. In this case Credit Life fees alone are $2,300. What am I missing?


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#33499 - 09/24/02 03:40 PM Re: HOEPA
JulesB Offline
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JulesB
Joined: Feb 2002
Posts: 324
A Designated Tree City in OK, ...
8% of $53,000 is $4,240. Your total points and fees are only $2,550 - less than the 8% of the loan amount threshold in your example.
Last edited by JulesB; 09/24/02 03:53 PM.
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#33500 - 09/24/02 04:21 PM Re: HOEPA
Kari Offline
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Kari
Joined: Sep 2002
Posts: 131
PA
Thank you for all the information. Am I making HOEPA harder than it is? The worksheet is great and the disclosures (vendors aren't helping us on this either). However, loan department is confused with the loan amount and amount financed on the worksheet from David. I am going to change the wording and wondered if it would alter the outcome. Also where can I find signs to say we are a HOEPA lender? One more question-- Starting Dec 26 in PA regading PA Act 55 my understanding is we have to offer insurance premiums by month instead of just single premium. Are we going through all this HOEPA pain for only 2 months? Any enlightenment on these questions is appreciated.

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#33501 - 09/24/02 05:25 PM Re: HOEPA
complyguy Offline
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complyguy
Joined: May 2001
Posts: 494
PA
Act 55 says that you can't offer only single premium insurance. The mandatory compliance date for this provision is 18 months to two years after Chapter 5's enactment date of 6/25/01.

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#33502 - 09/25/02 10:54 PM Re: HOEPA
SMQ, CRCM Offline
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SMQ, CRCM
Joined: Apr 2001
Posts: 4,828
Between the lines
In reply to:

loan department is confused with the loan amount and amount financed on the worksheet




If you are trying to use the worksheet and the FedDallas forms, I would advise against it. I spent 2 days confusing myself--that appraisal fee gave me fits. Or else I totally got all of this wrong and my examiner will have to explain it to all of us----very slowly.

David Dickinson has posted a great explanation in the General Threads under "HOEPA - Help Me! Help Me!"
Last edited by CAnderson; 09/26/02 12:52 PM.
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