We have had numerous inquiries over the past several months as to when the HOEPA worksheet will be updated for the January 2014 regulatory changes. We do not plan to update the HOEPA Worksheet for 2014’s High Cost Mortgages (previously HOEPA loans).
While we hate to take away a tool that so many have found useful over the years, there are a couple of reasons behind this decision.
- First, the “APR test” will now be able to be completed using the FFIEC’s rate spread calculator.
- Second, the “points and fees test”, under the new requirements, is much more individualized and includes many more ifs, ands, and buts than before. Thus, it would be nearly impossible for us to create a “one-size-fits-all” calculator.
In our discussions with bankers in the last month, we have heard of a couple software providers who are adding a “points and fees” calculation tool. We feel this would be a better option for most banks as they could hard code their specific fees rather than trying to utilize a generic calculator. We are encouraging banks to check with their software providers and/or request this service.
Please note: We will continue to include the 2013 HOEPA worksheet on our website for the duration of 2014. This way banks can still utilize it for their compliance reviews of older loans. We will include a warning so people do NOT use the 2013 version for 2014 loans.