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.
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?
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?
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?
10/29/2017
When the bank is refinancing a loan and the loan is subject to HOEPA, 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 rescission?
02/19/2017
Where can I find a HOEPA Worksheet?
01/29/2017
We made a loan in 2011 to a customer to purchase a property. The property had a residence and a commercial mechanics
garage with living quarters in it. At the time he bought this, he rented the house to his aunt and lived in the garage when he was in Missouri. He didn't reside here full time at that point. So we did this loan on our commercial side. We just found out his aunt has passed and he has been living full time in Mo. in the house. So knowing this, due to HOEPA or HPML etc ,are we required to move it to consumer side? Also where can I get further training on HOEPA and HMPL please?
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?
02/24/2014
If our lending policy prohibits making HOEPA mortgages what is the best denial reason and is the policy in violation of any regs?
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?