HOEPA DATE QUESTION

Posted By: wtlender

HOEPA DATE QUESTION - 04/21/08 03:46 PM

If the application date is 3/18/08 and consummation date is 4/15/08; what date is used for HOEPA to find the Treasury Security? February 15th?
Posted By: David Dickinson

Re: HOEPA DATE QUESTION - 04/21/08 04:36 PM

2/15/08 is correct. You use the "fifteenth day of the month immediately preceding the month in which the application for the extension of credit is received by the creditor."