Must all loans in which the points and fees exceed 5% be classified as High Cost loans pursuant to the Illinois High Risk Home Loan Act?
No. The Illinois High Risk Home Loan Act (HRHLA), 815 ILCS 137, is a separate and distinct statute from the APLD with its own requirements. For example, it does not apply to purchase loans. The APLD points and fees calculation is used solely as a standard for counseling. To determine whether a loan is High Cost, refer to the HRHLA and follow the procedures therein.
