What is the fee threshold set by the Federal Reserve Board that triggers HOEPA disclosures?
HOEPA. HOEPA requires the CFPB to annually adjust the total loan amount and fee thresholds that determine whether a transaction is a high cost mortgage. In the final rule, for 2022, the CFPB increased the total loan amount threshold to $22,969, and the current points and fees threshold to $1,148.
What percentage is the fee threshold that triggers HOEPA disclosures for loans below $21980?
8%
Loans below $21,980 will also be considered a high-cost transaction if the points and fees exceed the lesser of 8% of the total loan amount or $1,099.
What loans are 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.
Who enforces Tila respa?
The Consumer Financial Protection Bureau (CFPB)
The TILA RESPA Integrated Disclosure (TRID) rule’s October 3rd implementation deadline has passed. This massive rule weighs in at nearly 2,000 pages and impacts all businesses that touch a residential mortgage, as well as homebuyers. The Consumer Financial Protection Bureau (CFPB) is enforcing this rule.
What is the maximum amount that a borrower can prepay without penalty?
Amount Limitations for Prepayment Penalties For the first two years after the loan is consummated, the penalty cannot be greater than 2% of the amount of the outstanding loan balance. For the third year, the penalty is capped at 1% of the outstanding loan balance.
What is an example of a trigger term?
Examples of Triggering Terms The amount of a down payment expressed as a percentage or a dollar amount (example: “5% down” or “80% financing”) The amount of any payment expressed as a percentage or a dollar amount (example: “$15 per month” or “monthly payments of under $100”)
Is no annual fee a triggering term?
Trigger terms are words or phrases, whether positively or negatively mentioned (e.g., “no annual fee”), that prompt additional regulatory disclosures in the headline, subhead, and/or disclosure of the advertisement to clarify the credit costs and terms that are being promoted.
What terms are allowed in a high cost mortgage?
High-cost mortgages must meet the same three requirements that pertain to higher-priced mortgages, but in addition to these, the following conditions apply, among others: no balloon payment is allowed; the creditor cannot recommend default; the maximum allowed late fee is 4 percent of the past-due payment; points and …
