Compliance Blog

The Federal Reserve has announced the annual change in the HOEPA Trigger.  Unlike my 401K, this amount always goes up.

Annually, the FRB revises the minimum threshold for the total amount of points and fees that require lenders to provide borrowers disclosures mandated by HOEPA. Effective January 1, 2009, the minimum threshold for total fees and points will increase from $561 to $583. This adjustment does not affect the new rules for “higher-priced mortgage loans” adopted by the FRB in July 2008. If the total points and fees exceed the greater of $583 or 8 percent of the loan amount, Section 32 of Regulation Z requires lenders to provide borrowers additional disclosures. Credit insurance premiums for insurance written in connection with the credit transaction are fees for the purpose of this computation.

NCUA issued Regulatory Alert 08-RA-04 to summarize the change.  It provides a great deal of background information about HOEPA and when it applies.  The italicized text above comes from that RA.

Back to my 401K.  Recent events have caused me to rethink my age of retirement.  According to my recent calculations, I'll now retire at 93.  Give or take a year.  Ugh.