HOEPA Flashcards
1
Q
What is are the main reasons for implementing HOEPA?
A
To protect borrowers who are consumers of ‘High Cost Mortgages’.
2
Q
Implementing Regulations for HOEPA:
A
Regulation Z, Sections 31, 32, and 34
3
Q
What is the APR threshold for First Lien Mortgages?
A
APR that is 6.5 percentage points above the average prime offer rate.
4
Q
What is the APR threshold for Second Lien Mortgages?
A
APR that is 8.5 percentage points above the average prime offer rate.
5
Q
A home loan may also be a high cost mortgage if it includes:
A
- a prepayment penalty provision that is in force for more than 36 months after consummation, or
- prepayment penalties that exceed more than 2% of the amount prepaid.
6
Q
The Dodd-Frank Act amendments to HOEPA expanded the scope to include what types of loans?
A
- Home purchases or home construction
2. Open-end and Closed-end home equity plans
7
Q
Disclosures for HOEPA are due:
A
at least 3 days before consummation.
