Effective January 1, 2014, the fee based trigger amount used to calculate whether a loan is subject to HOEPA was 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.
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!