Hoepa points and fees test
[PDF File]HOEPA Loans under the Dodd-Frank Act
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HOEPA Points and Fees Calculation * A bona fide discount point for closed-end loans is 1% of the loan amount paid by the borrower that reduces the interest rate for the transaction.For open-end loans, it is 1% of the plan’s credit limit when the account is opened, paid by the borrower and reduces the interest rate.
[PDF File]QM Points & Fees: Included and Excluded
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QM Points & Fees: Included and Excluded 12906 INCLUDED IN QM’S POINTS AND FEES NOTES Most items in the finance charge Most charges in the finance charge are included in the points and fees, with some exceptions. Exceptions are listed in the Charges Excluded From QM’s Points and Fees Calculation chart immediately following this one.
[PDF File]QM / HOEPA** / TRID APR / Finance Charges GSE***
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Refer to QM / HOEPA Comments Do not include if this is NOT a finance charge Discount Fee / Discount Points NO; A B; C N/A; YES YES; YES YES; Refer to QM / HOEPA comments Up to 2 bona fide discount points can be exluded provided the loan meets certain requirements. Refer to the FAMC Discount Points Policy for detailed requirements. Doc Imaging ...
[PDF File]Working with HOEPA and Ability-to-Repay Regulations
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Points and Fees Test Section .....43 Prepayment Penalty Threshold Test ... •Points and fees do not exceed 3% of the Regulation Z-defined Total Loan Amount (for loan amounts less than $100,000, higher percentage thresholds are ... of the APR used in the HOEPA Rate Threshold test only, a creditor shall
[PDF File]Section 32 (HCM/HOEPA) Breakdown
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APR Test: A closing date APR that exceeds the APOR as of the date the interest rate was set 6.5 % points for first-lien loans or 8.5 % points for subordinate-lien loans 8.5 % points for first-lien loans if dwelling is personal property and less than $50,000 -OR- Points and Fees Test: Points and fees exceeding the greater of;
[PDF File]Qualified Mortgage (QM) Points and Fees Worksheet
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Qualified Mortgage (QM) Points and Fees Worksheet ... or affiliate fees that must be considered in the QM points and fees test (e.g., mortgage insurance premiums, credit life insurance) $ ... Enter the APR used in the calculation to establish that the loan is NOT HOEPA High Cost. Ver 3.14.17 Exhibit 31 Job Aid …
[PDF File]Home Ownership and Equity Protection Act (HOEPA) Rule
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3.6 What is the points-and-fees coverage test? ..... 18 3.7 What do I include when calculating points and fees for HOEPA ... closed-end home equity loans with high interest rates or high fees. Since HOEPA’s enactment, refinances or home equity mortgage loans meeting any of HOEPA’s high-cost coverage tests
[PDF File]Ability -to-Repay and Qualified Mortgage Rule
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Ability -to-Repay and Qualified Mortgage Rule . The Bureau recently finalized changes to this rule. The June 2013 ATR/QM Concurrent Final Rule, July 2013 Final Rule, and October 2013 Final Rule amend the final rule issued January 10, 2013, which is set to take effect on January 10, 2014. This guide is updated for these changes.
[PDF File]Ability-to-Repay & Qualified Mortgages
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Real Estate Settlement Fees: Conditional Exclusions §Real estate settlement costs • Costs described in the Truth in Lending finance charge rule 1026.4(c)(7) o Title-related charges, appraisal fees, credit report fees, and document preparation fees, etc §To be excluded, the fees must meet 3 conditions: 1. Reasonable 2. Without direct or indirect compensation to the creditor, and
HOEPA Worksheet
Exempt Loan: HOEPA only applies to purchase or refinance loans secured by a borrower’s primary residence and not originated or made by a Housing Finance Agency (HFA). 2. Total Points and Fees: The total amount of points and fees, expressed in dollars, calculated in accordance with Regulation Z, Truth in Lending, 12 C.F.R. 1026.32 (b)(1). 3.
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