TILA Reg Z

Question 1

In order to be covered under Reg Z, the primary purpose must be what?

Answer 1

for personal, family or household

Question 2

What are some non exceptions to Reg Z?

Answer 2

Loan greater than 57,200 (2019)

• -if secured by principal dwelling or real property(land or dirt) or
• -any purpose of loan is for secondary education

Question 3

What are some examples of open end credit in Reg Z?

Answer 3

credit cards, overdraft, HELOC

Question 4

True or False

Disclosures must be given to both borrower and co-borrower.

Answer 4

False

Just one set is required but bank may provide to both

Question 5

For open end credit, what is the APR composed of?

Answer 5

Only the interest rate

Question 6

Is application fee paid by all applicants a finance charge?

Answer 6

No

Question 7

Are prepaid finance charges included in amount financed?

Answer 7

No

Question 8

what transactions are covered under ATR?

Answer 8

• -individual borrower
• -personal purpose
• -closed end
• -secured by dwelling (residential structure 1-4 units)

Question 9

What options does a bank have to meet ATR requirements?

Answer 9

• -collect information for underwriting
• -refinance a non-standard loan to a standard loan
• -qualified mortgage

Question 10

What is a safe harbor QM?

Answer 10

APR below HPML threshold of 1.5% basis points above APOR if secured by first lien; 3.5% if secured by junior lien

Question 11

What is rebuttable presumption QM?

Answer 11

APR is above threshold for safe harbor QM?

Question 12

A loan cannot be a QM if it contains any of the following

Answer 12

• -negative amortization
• -interest only
• -term greater than 30 years
• -balloon payment (unless small creditor)
• -DTI greater than 43% (unless meets GSE purchase or government guarantee or insurance test
• -points and fees above threshold (established annually)