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Latest Lending - HOEPA Topics

Exceptions to HOEPA and HPMLs

12/17/2023

Are short term loans (loans that will not be satisfied and replaced with permanent financing; paid out in full instead) subject to HOEPA and HPML? I see that temporary loans and bridge loans -12 months or less (loans that will be satisfied and replaced with permanent financing) are not subject to HPML. I believe temporary and short term loans are subject to HOEPA though.

Code 3 on HMDA LAR Report (HOEPA)

11/03/2019

As to a loans HOEPA status, are second homes and vacation homes considered not applicable for HOEPA which would make the status code 3 on the HMDA LAR report?

Test HOEPA at the Time of Loan Estimate?

12/23/2018

Should HOEPA be tested at the time of a Loan Estimate? Our system will let us test for it at time of Closing Disclosure, but should it actually test at LE time?

Prohibition-Structuring Loan to Evade Requirements

03/04/2018

1026.34 cites a prohibition on structuring loans to evade requirements. Would this include reducing the interest rate on a loan to avoid HOEPA? If we can do this, are there any fair lending or UDAAP considerations?

HOEPA Consuling Fee-Added as Free Charge?

10/29/2017

When the bank is refinancing a loan and the loan is ​subject to ​H​OEPA, the customer has to go to consuling. After the LE is given, the customer comes back and says he cannot afford the $100.00 consuling fee. Can that fee be added as a fee charge or should it be added to the amount requested? If added to the amount requested, does this trigger a right of re​scission?

Where to Get Training on HOEPA & HPML

01/29/2017

We made a loan in 2011 to a customer to purchase a property. ​T​he property had a residence and a commercial mechanic​s​ garage with living quarters in it. ​A​t the time he bought this, he rented the house to his aunt and lived in the garage when he was in Missouri. ​H​e didn't reside here full time at that point. ​S​o we did this loan on our commercial side. ​W​e just found out his aunt has passed and he has been living full time in Mo. in the house. ​S​o knowing this, due to HOEPA or HPML etc ​,​are we required to move it to consumer side? ​A​lso where can I get further training on HOEPA and HMPL please?

How to Calculate High Cost Mortgage Limits-HELOC

02/02/2015

How do I calculate the high cost mortgage limits for a HELOC? I see the APOR sheet published online but I am not sure what term to look at. Our HELOC is a 10 year draw with a 10 year repay. Am I looking at the 10 year column or the 20 year column?

HOEPA Requirements- $50,000 Exemption

02/10/2014

Am I reading 1026.32 correctly that if you have a loan of $50,000 or more secured only by a first-lien on a manufactured home, it is exempt from high-cost (a/k/a HOEPA) requirements?

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HMDA - Getting it Right!

04/06/2025

Have you been looking for the 2025 HMDA Getting It Right! Guide on the FFIEC website? We couldn't find it either.

Reporting loans with two AUS reports

04/06/2025

If underwriting pulls two AUS reports trying to get the customer approved for FannieMae and Freddie Mac, do we report both results or only the last one completed that shows approved or ineligible?

VA loan and required Texas fee

04/06/2025

Is the Attorney Document Preparation Fee that the state of Texas requires an allowable fee to be charged to the borrower on a VA loan?

Disclosing title fees on the loan estimate

03/30/2025

For our portfolio mortgage loans we disclose title fees in the section of the loan estimate marked "borrower allowed to shop for" since we do not usually have a detailed fee quote before the loan estimate is required. A closing fee or settlement fee usually charged by the title company is a prepaid finance charge. Should we disclose a Title Closing fee and mark it PPF on the loan estimate even without an exact quote so that we do not have to do a new loan estimate for a changed circumstance due to a change in APR exceeding .125 when fees do come in prior to sending the closing disclosure?

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