HOEPA

Question 1

The criteria for a high-cost loan are:

Answer 1

• First-lien transaction is more than 6.5 percent higher than the prime offer rate.
• Junior lien transactions are more than 8.5 percent higher than the prime offer rate.
• Total fees and points payable by the consumer at or before closing exceed five percent of the total loan amount.

Question 2

Higher-priced loans are ones in which the APR exceeds the Average Prime Offer Rate by at least:

Answer 2

• 1.5% for first-lien loans
• 2.5% for a jumbo loan
• 3.5% for a subordinate lien