Posted on: 22nd Sep, 2008 11:53 am
If we offer a home equity product to a member who does not have a first mortgage would we use the 8% or 10% thresh hold to determine if it falls under HOEPA?
Hi englandj!
I do not think that home equity loans can be offered to a member who does not have a first mortgage.
8% can be used in case of 1st liens or 10 in case of junior liens if the person has a first mortgage. In some states there can be lower thresholds like 7% for a 1st lien.
I do not think that home equity loans can be offered to a member who does not have a first mortgage.
8% can be used in case of 1st liens or 10 in case of junior liens if the person has a first mortgage. In some states there can be lower thresholds like 7% for a 1st lien.
i don't know the ins and outs of the HOEPA requirements, but there is no reason you cannot use the home equity product as a first mortgage.
