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FDIC Clarification to Banks Offering Products and Services to Non-Bank Payday Lenders (FIL-52-2015)

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HOEPA Points and Fees Worksheet for Closed-End Loans Before 1/10/14

This HOEPA fees & points worksheet calculates whether a closed-end mortgage loan originated after January 10, 2014, must comply with HOEPA because of the size of its points and fees. It calculates trigger fees, the “total loan amount,” and the trigger fees as a percentage of the “total loan amount.” Other NCLC practice tools provide worksheets for open-end mortgage loans originated on or after January 10, 2014, and for closed-end mortgage loans originated prior to January 10, 2014.

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HOEPA Points and Fees Worksheet for Open-End Loans On or After 1/10/14

This HOEPA fees and points worksheet calculates whether an open-end mortgage loan originated after January 10, 2014, must comply with HOEPA because of the size of its points and fees. It calculates trigger fees, the “total loan amount,” and the trigger fees as a percentage of the “total loan amount.” Other NCLC practice tools provide worksheets for closed-end mortgage loans originated on or after January 10, 2014 and for closed-end mortgage loans originated prior to January 10, 2014.

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2010-24: Combined Loan-to-Value Requirements for Refinance Transactions (Superseded by 10-36)

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2010-04: Loss Mitigation for Imminent Default

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2009-35: FHA Loss Mitigation Incentives (Update) (Sept. 23, 2009)

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2009-32: Revised Streamline Refinance Transactions (Sept. 18, 2009)

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2010-36: Requirements for Combined Loan Amounts

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96-68: Disposition of Assignment Requests (Nov. 29, 1996)

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96-65: Procedural Changes for Single Family Servicing and Single Family Claims (Dec. 2, 1996)

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Fees for Expedited Service Are Permissible (Interp. Letter 1069, Aug. 2006)

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Industrial Loan Companies Cannot Be Prohibited by State Law from Opening Branches (Interp. Letter 1068, July 2006)

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Letter from House Fin. Svcs. Committee to OCC re Preemption (Sept. 27, 2005)

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OCC Reply re Preemption (Nov. 22, 2005)

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Performance of Escrow Activities by a National Bank (Interp. Letter 1041, Oct. 2005)

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Remote Deposit Capture Terminals (Interp. Letter 1036, Aug. 2005)

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Preemption re Check-Cashing Fees (Conn.) (Interp. Letter 1055, Aug. 2005)

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Preemption re Check-Cashing Fees (Interp. Letter 1054, July 2005)

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Preemption Interpretation (May 10, 2001)

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Preemption Interpretation (Mar. 20, 2000)

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Operating Subsidiaries and Most Favored Lender Doctrine (July 20, 2006)

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Preemption of State Gift Card Restrictions (June 9, 2006)

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Calculation of Consumer Loan Limits for Auto Lending (May 18, 2006)

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Preemption of Certain Lending-Related Provisions in the Code of Montgomery County, Maryland (Mar. 7, 2006)

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Illinois Corporate Fiduciary Act (Oct. 28, 2004)