[Anonymous]

Is the “Finance Charge and the Total of points and Fees Calculator” given to us a couple of meetings ago, to be used for ATR as well as the new HOEPA calculations? I had in my notes for HOEPA that you use the same determination for points and fees as you would for ATR so I am assuming this calculator would work for both?

Also, when is the CFPB supposed to have their lists of homeownership counselors available?

Thanks!

Topic

[rcooper]

Yes, see in the ATR rules below that it references the high cost mortgage points and fees test.
1026.43(e)(3): Limits on points and fees for qualified mortgages. (i) A covered transaction is not a qualified mortgage unless the transaction’s total points and fees, as defined in § 1026.32(b)(1), do not exceed…

And I haven’t heard anything on the CFPBs list of homeownership counselors. Let’s hope they have it available by the effective date of January 10th.

[Author]

Replies