Is HOEPA part of Reg Z?

Section 32 of Regulation Z implements the Home Ownership and Equity Protection Act of 1994 (HOEPA). HOEPA protects consumers from deceptive and unfair practices in home equity lending by establishing specific disclosure requirements for certain mortgages that have high rates of interest or assess high fees and points.

What loans are subject to HOEPA?

Most types of mortgage loans secured by a consumer’s principal dwelling are potentially subject to HOEPA coverage, including purchase-money mortgages, refinances, closed-end home equity loans, and open-end credit plans (home equity lines of credit or HELOCs).

What is HOEPA form?

The Home Ownership and Equity Protection Act (HOEPA) was enacted in 1994 as an amendment to the Truth in Lending Act (TILA) to address abusive practices in refinances and closed-end home equity loans with high interest rates or high fees.

What is HOEPA threshold?

For HOEPA loans, the adjusted total loan amount threshold is $20,391, effective January 1, 2015. The adjusted statutory fee trigger for HOPEA loans is $1,020, effective January 1, 2015.

Does HOEPA allow prepayment penalties?

HOEPA prohibits prepayment penalties for high-cost mortgages. Added prepayment penalty coverage test: More than 36 months after consumption or account opening.

What is exempt from HOEPA?

Loans Exempt from HOEPA Coverage Reverse mortgages. Construction Loans (applies to only the initial construction of a new dwelling) Loans originated and directly financed by Housing Finance Agency (HFA) Loans originated under the U.S. Department of Agriculture (USDA’s) Rural Development Loan Program.

What are the 8 ATR rules?

At a minimum, creditors generally must consider eight underwriting factors: (1) current or reasonably expected income or assets; (2) current employment status; (3) the monthly payment on the covered transaction; (4) the monthly payment on any simultaneous loan; (5) the monthly payment for mortgage-related obligations; …

How do I know if my loan is a HOEPA?

How to Determine if a Loan is Considered a “High-Cost Mortgage” A loan is considered high-cost if the transaction’s annual percentage rate (APR) exceeds the Average Prime Offer Rate (APOR) for comparable transactions on that date more than: 6.5 percentage points for first-lien transaction.

When did HOEPA update small entity Compliance Guide?

On November 16, 2018, the Bureau updated the small entity compliance guide to reflect changes made by the Economic Growth, Regulatory Relief, and Consumer Protection Act. Browse HOEPA final and interpretive rules to see specific amendments made by each final rule to Regulations Z and X.

What does HOEPA stand for in Consumer Protection Act?

Historically, these transactions have been referred to as “HOEPA loans” or “Section 32 loans.” This guide refers to such transactions as “high-cost mortgages,” which is consistent with the terminology used in the Dodd-Frank Wall Street Reform and Consumer Protection Act (the Dodd-Frank Act) and the 2013 HOEPA Rule.

Where can I find the regulations for HOEPA?

Browse HOEPA final and interpretive rules to see specific amendments made by each final rule to Regulations Z and X. Browse Regulation Z (12 CFR 1026) on: Interactive Bureau Regulations | eCFR Browse Regulation X (12 CFR 1024) on: Interactive Bureau Regulations | eCFR Main HOEPA rule provisions and official interpretations can be found in:

What does section 32 mean on a HOEPA loan?

Historically, these transactions have been referred to as “HOEPA loans” or “Section 32 loans.” This guide refers to such transactions as “high-cost mortgages,” which is consistent with the terminology used in the Dodd-Frank Wall Street Reform and Consumer Protection Act (the Dodd-Frank Act) and the 2013 HOEPA Rule.

https://www.youtube.com/watch?v=rdOpsTLvbeY