The Points & Fees Test thresholds used to determine whether a loan is a High Cost Mortgage (HCM) will increase on January 1, 2015. A loan will be considered a HCM if:
• The loan amount is at least $20,391 AND the points & fees exceed 5% of the total loan amount. This is up from $20,000 in 2014.
• The loan amount is less than $20,391 and the points & fees exceed the lesser of 8% of the total loan amount or $1,020. This is up from $1,000 in 2014.
As a reminder, there are 3 separate “tests” to determine HCM status (an APR test, a points & fees test and a prepayment penalty test) and if a loan meets the criteria of any one of the 3 tests, it is a HCM. The points and fees test is the only test where thresholds adjust annually.
Amy brings many years of banking and compliance experience to Banker’s Compliance Consulting. She has worked for both large and small financial institutions and spent time working in every area of a bank. She started out as a teller in college and eventually became a branch manager.
Her love, however, was always compliance. Amy began her career with Banker’s Compliance Consulting in 2000. Her knowledge and experiences have allowed her to develop a well-rounded and practical approach to regulatory compliance. Amy is CRCM certified, has a Bachelor’s Degree in Business Administration, and is a graduate of the ABA Compliance School.
Amy & her husband have two children at home and stay busy following their activities. They spend a lot of time in the bleachers!