Effective for loans originated on or after January 1, 2021,
CFPB’s Final Rule updates the dollar amounts for provisions
implementing amendments to Truth-in-Lending Act (TILA)
under the Home Ownership and Equity Protection Act (HOEPA) and the Dodd-Frank Act.
Accordingly, Sun West will be updating the following sections of its Implementation Guide:
Home Ownership and Equity Protection Act (HOEPA)
The Loan Amount Thresholds and Points and Fees Limit used to determine whether
a transaction is a High Cost Mortgage are revised as below:
Loan Amount Threshold | Points and Fees Limit |
Loan Amount $22,969 | 5% of Total Loan Amount |
Loan Amount < $22,969 | 8% of Total Loan Amount or $1,148, whichever is less |
Dodd-Frank Act - Ability to Repay/Qualified Mortgage (QM)
The Loan Amount Thresholds and Points and Fees Limits used to determine
whether a transaction is a Qualified Mortgage (QM) are revised as below:
Loan Amount | Points and Fees Limit |
Loan Amount $114,847 | 3% of Total Loan Amount |
$68,908 Loan Amount < $114,847 | $3,445 |
$22,969 Loan Amount < $68,908 | 5% of Total Loan Amount |
$14,356 Loan Amount < $22,969 | $1,148 |
Loan Amount < $14,356.1 | 8% of Total Loan Amount |
The Total Loan Amount is calculated by subtracting any points and
fees that are financed by the creditor from the amount financed.
Sincerely,
C G
Sun West Mortgage Company, Inc.
6131 Orangethorpe Avenue, Suite 500
Buena Park, California 90620
Phone: (949) 784- 9699
|