Does the requirement in Regulation C to report HOEPA status impose any new obligations on lenders?
Under the amendments to Regulation C, lenders are required to report whether a loan is subject to the requirements of HOEPA. The amendments to Regulation C do not, however, affect any of HOEPA’s requirements or limitations. Lenders should already have in place procedures for monitoring and complying with the provisions of HOEPA. Other Items in HMDA Data that Aid Interpretation of Price Data 22. Why must lenders report the lien status of a loan? Lenders report whether a loan is or would be secured by a lien on a dwelling and, if so, whether a first lien or a subordinate (junior) lien. A loan’s lien status determines what rate-spread reporting threshold applies to the loan (see Q. 9, 10). Also, because lien status is an important determinant of loan price (interest rates on first-lien loans are generally lower than rates on junior-lien loans), lien status differences may explain some price disparities. 23. Why must lenders identify loans involving manufactured homes? HMDA has long requir
Related Questions
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