HOEPA Worksheet for Loans after 10/1/09

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Question:

Is there a HOEPA worksheet available that is for loans after 10/1/09? My understanding is that if the APR on a first lien principal dwelling loan exceeds the average prime rate offer by 1.50%, the loan is considered a HOEPA loan.

Answer:

We offer a HOEPA worksheet for free. You can download it here. However, you are mixing HOEPA and High Priced Mortgage Loans (HPML). The 1.5% spread is for HPML, not HOEPA loans. The FFIEC has a new rate spread calculator at their website.

First published on BankersOnline.com 12/07/09