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HOEPA Disclosures & Closedend Home Equity Loans

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Question: 
Is the HOEPA disclosure necessary for each and every closedend home equity loan or only the loans that meet the outlined criteria? Perhaps a better question would be this: do specific outlined criteria exist such that all the types of nonHELOC loans would ultimately fall under HOEPA?
Answer: 

No. HOEPA disclosures are only needed on consumer purpose refinance, home equity or home improvement loan, secured by the borrower’s principal dwelling and either:

  1. Exceed the maximum APR, or
  2. Exceed the maximum fee percentage.

First published on BankersOnline.com 9/22/03

First published on 09/22/2003

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