HOEPA Threshold Updated

Effective January 1, 2014, the fee based trigger amount used to calculate whether a loan is subject to HOEPA BSA Training and Banking Regulations Compliance Consulting amy11 - HOEPA Threshold Updatedwas increased to $632.  This is up from the 2013 trigger amount of $625.

Please note that this trigger amount will only be applicable to loans closed from January 1, 2014, to January 9, 2014 (really only 6-7 business days, depending on your bank).  This is due to the fact that applications on or after January 10, 2014, will be subject to the new High Cost Mortgage requirements in Truth in Lending.

We do not plan to create a 2014 HOEPA Worksheet for such a short period of time.  The likelihood of having a loan application with fees between $625-$632 in a 6-7 day period is very small.  Thus, you could still use the 2013 HOEPA Worksheet to assist you during this time.

Published
2014/01/01
Amy Kudlacek

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