HOEPAHome Ownership and Equity Protection Act of 1994
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The new rules also changed the benchmark used to identify high-cost loans that are covered by HOEPA's protections.
The study committee continuously rejected industry arguments that assignee liability based on common law claims of wrongdoing would impact the willingness of lenders to lend or purchasers to purchase, as has been the case under HOEPA. It will impact their willingness to support the Uniform Home Foreclosure Procedures Act.
First, there's a difference: if HPMLs are bad loans, HOEPA loans are really ugly loans.
HOEPA was enacted under the Riegle Community Development and Regulatory Improvement Act of 1994 in response to abusive practices in mortgage refinance and home-equity lending.
These triggers were so high, as of 2007, that HOEPA regulated no more than 1% of subprime home loans (Gramlich 2007).
The conference report accompanying the Dodd-Frank Act indicates that the 'Federal Reserve Board failed to meet its responsibilities under HOEPA, despite persistent calls for action.' (199) The Report highlights that
Owners' Equity Protection Act (HOEPA) by revising the definition of
(150) The Federal Home Ownership and Equity Protection Act (HOEPA) is a set of amendments to the Truth in Lending Act requiring certain disclosures and prohibiting oppressive terms in home-secured loans.
ABAWorks on Regulation Z: What the New Rules on Mortgage Lending and HOEPA Mean to Your Bank (updated September 2009).
In addition, the federal supervisors also check whether banks are obeying laws and consumer protections such as the Home Mortgage Disclosure Act (HMDA), the Equal Credit Opportunity Act (ECOA), the Truth in Lending Act (TLA), the Real Estate Settlement Procedure Act (RESPA), and the Home Ownership Equity Protection Act (HOEPA).