Post by Sapphire Capital on Aug 22, 2014 21:21:57 GMT 4
On August 15th, the Consumer Financial Protection Bureau (“CFPB”) issued amendments to the dollar threshold amounts under Regulation Z. The minimum interest charge disclosure thresholds will remain unchanged in 2015. The adjusted dollar amount for the penalty fees safe harbor in 2015 will be $27 for a first late payment and $38 for each subsequent violation within the following six months. For Home Ownership and Equity Protection Act (“HOPEA”) loans, the adjusted total loan amount threshold is $20,391, effective January 1, 2015. The adjusted statutory fee trigger for HOPEA loans is $1,020, effective January 1, 2015. Effective January 1, 2015, for the purpose of creditor’s determination of a consumer’s ability to repay a transaction secured by a dwelling, a covered transaction is not a qualified mortgage unless the transaction’s total points and fees do not exceed 3 percent of the total loan amount for a loan greater than or equal to $101,953; $3,059 for a loan amount greater than or equal to $61,172 but less than $101,953; 5 percent of the total loan amount for a loan greater than or equal to $20,391 but less than $61,172; $1,020 for a loan amount greater than or equal to $12,744 but less than $20,391; and 8 percent of the total loan amount for a loan amount less than $12,744. The amendments are effective January 1, 2015. 79 FR 48015.
General information only, this is no legal or financial advice or legal opinion and no solicitation or offering of services. Use of posted information should be contingent on your counsel advise on a case by case basis.