Alert August 11, 2009

FRB Adjusts HOEPA Loan Fee Trigger

The FRB published its annual adjustment to the dollar amount of fees that triggers additional requirements and limitations under the Truth in Lending Act for home mortgage loans having rates or fees above a certain amount. The new dollar amount of the fee-based trigger is $579, effective January 1, 2010. The adjustment applies to so-called HOEPA loans, not to the new rules, adopted in July 2008, for "higher-priced mortgage loans." The rules for higher-priced mortgage loans use a different rate-based trigger. Click here for the Federal Register notice announcing the adjustment to the HOEPA loan fee trigger.