By Amy Kudlacek
Each year the FRB adjusts the threshold for the “points and fees test” to determine if a loan is subject to §1026.32 of Reg Z (aka “HOEPA”). The June 20, 2011 Federal Register announced the threshold as $611 for 2012:
Effective January 1, 2012, for purposes of determining whether a home mortgage transaction is covered by 12 CFR 1026.32 (based on the total points and fees payable by the consumer at or before loan consummation), a loan is covered if the points and fees exceed the greater of $611 or 8 percent of the total loan amount.
We have posted an updated HOEPA Worksheet (Version 2012-1) on the free downloads page of our website. If you save a copy of the HOEPA Worksheet on your computer don't forget to download the new version. We will continue to make the 2011 HOEPA worksheet available on the website as well to assist you in your loan compliance audits.