Reg C, HOEPA, and Maturity

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Question:

This is in reference to Reg C and HOEPA. Our program that we use for closed end consumer credit has only 1 spot to input the treasury maturity. Are we okay using the 10 year maturity only?

Answer:

For each loan, you should use the Treasury securities index that is closest to the term of the loan. If you can only insert one index, the tenyear, you have a problem. Either you can only make 10year loans or you need to change your software.

First published on BankersOnline.com 9/15/03