HOEPA

Question 1

What does HOEPA stand for?

Answer 1

Home Ownership and Equity Protection Act

Question 2

What regulation is HOEPA affiliated with?

Answer 2

Regulation Z

Question 3

Who administers and enforces HOEPA?

Answer 3

Consumer Financial Protection Bureau (CFPB)

Question 4

What is the purpose of HOEPA? Name two…

Answer 4

• Creates certain protections under TILA for loans with higher interest rates and high fees. This was the first legislation specifically created to combat the practice of predatory lending.; and
• Prohibits certain actions that improperly influence appraisers

Question 5

What are two other names for HOEPA loans?

Answer 5

Section 32 or High Cost Loans

Question 6

What is loan flipping?

Answer 6

Loan flipping is the practice of repeated refinancing of a loan within a short period of time.

Question 7

What is equity stripping?

Answer 7

Making loans based on the amount of equity in a home, without verifying the borrower’s ability to repay (ATR).

Question 8

When do delivery requirements for HOEPA loans require that disclosures are due?

Answer 8

At least 3 business days prior to closing

Similar to TILA

Question 9

Loans that fall in the scope of HOEPA loans require additional “disclosure” requirements. Name three of these requirements.

Answer 9

• Special HOEPA Disclosure;
• Notice of balloon payment;
• Amount borrowed;
• Notice of the inclusion of insurance premiums;
• Variable-rate disclosure