Another HOEPA Form Required if the Rate Changes?

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Question:

Which forms are required to be redone with a rate change? There was not a rate lock; however, the rate went down before closing. If the rate changes before closing, is another HOEPA form required?

Answer:

Regulation Z Section 1026.31(c)(i) indicates you must provide new disclosures if the creditor changes any term that makes the disclosures inaccurate. Whether it was a rate lock or not, doesn't matter. Review this section and its commentary for more information.

First published on BankersOnline.com 3/12/12