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High-Cost Mortgages

On Jan. 10, the CFPB issued a final rule that expands the coverage of the “high cost” mortgage designation and increases the restrictions on these loans. The rule, required by the Dodd-Frank Act, expands HOEPA to cover home-purchase loans and home equity lines of credit; revises the law’s rate and fee thresholds for coverage; and adds a new coverage test based on a transaction’s prepayment penalties.

ABA's Position

ABA’s September 2012 comment letter on the Bureau’s proposed rule warned that the rule’s provisions are over-inclusive and not well-coordinated with other proposed rules. Deeper analysis is necessary to ensure that credit is not unduly restricted and to ensure that the regulation’s provisions are more clearly directed toward those it intends to protect. ABA offered a survey revealing that the proposed HOEPA triggers will have a measurable negative effect on already depressed lending levels.

Recent News


 Comment Letters


 ABA Analysis


 Final Regulations


​For more information please contact Rod Alba 


 ABA Staff Contacts

  • Rod Alba, Sr. Vice President, ABA  Mortgage Fin/Sr. Regulatory Counsel

 ABA Resources