HOEPA Pre-purchase Counseling
Based on recent amendments to the Home Ownership and Equity Protection Act (HOEPA), borrowers of certain types of mortgages are now required to complete pre-purchase housing counseling with a HUD-approved agency before closing the loan. As a nonprofit HUD-approved housing counseling agency, Springboard has compiled important information you need to know about the new regulations:
- HOEPA Lender Guide
- CFPB Compliance Guide
- Downloadable Reference Guides
Get Pre-purchase Counseling
Priority Pre-purchase Counseling℠ from Springboard gets you:
- Priority Counseling Request
Call for an immediate, stream-lined session.
- Electronic Certificate Delivery
Immediately sent to you and your lender upon completion of counseling.
- GFE Secure Delivery℠
Ability for borrowers to send their good faith estimate in advance, expediting the counseling process.
The 2013 HOEPA Rule applies to loan applications received on or after January 10, 2014. To comply with high-cost mortgage provisions of this rule you must:
- Give additional disclosures
- Avoid certain loan terms
- Ensure the consumer receives additional protections including homeownership counseling
Creditors must provide a list of homeownership counseling organizations within 3 days of application, and confirm that the consumer received homeownership counseling.
Loans Subject to HOEPA Coverage
- Purchase-money mortgages
- Closed-end home equity loans
- Open-end credit plans (i.e. HELOCs)
Loans Exempt from HOEPA Coverage
- Reverse mortgages
- Construction Loans (applies to only the initial construction of a new dwelling)
- Loans originated and directly financed by Housing Finance Agency (HFA)
- Loans originated under the U.S. Department of Agriculture (USDA’s) Rural Development Loan Program
- Mortgages secured by vacation or second homes
How to Determine if a Loan is Considered a “High-Cost Mortgage”
A loan is considered high-cost if the transaction’s annual percentage rate (APR) exceeds the Average Prime Offer Rate (APOR) for comparable transactions on that date more than:
- 6.5 percentage points for first-lien transaction
- 8.5 percentage points for first-lien that are for less than $50,000 & secured by personal property (i.e. houseboat, RVs)
- 8.5 percentage points for junior-lien transactions
A loan is also determined to be high-cost by the amount of points & fees paid within the transaction, or by its prepayment penalties. The APOR is published at www.ffiec.gov/ratespread.