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Threshold for Loan Amount Exempt from HOEPA

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Question: 
We are making a loan in the amount of $4500 for one year against the borrowers primary residence for the purpose of paying delinquent real estate taxes. The rate will be 7.50% and total fees will be less than $528. The loan is not an HPML, but what about HOEPA? The APR will be over the 8.00% plus treasury but my fees will be less than $528.00. Is there any threshold for a loan amount to be exempt from HOEPA. Please advise.
Answer: 

Is there any threshold for a loan amount to be exempt from HOEPA.

No. Regardless of loan amount if it exceeds the APR or fees and charges threshold then it is subject to HOEPA.

First published on BankersOnline.com 6/24/13

First published on 06/24/2013

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