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High-Cost Mtg HELOCS

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  • #4034
    shea930
    Participant

    In the Repayment ability – Presumption of Compliance it states we must “If the annual percentage rate may increase during the plan, the maximum annual percentage rate that is included in the contract, as required by 1026.30, applies to the plan at account opening and will apply during the draw period and any repayment period.

    I just want to make sure I understand correctly. Does this mean if our variable rate on our HELOC is Prime + 1.00 which would be 4.25, however we have a ceiling of 21.00%…..do we have to calculate our payment using the 21%??

    #4040
    jholzknecht
    Keymaster

    Yes.

    #4080
    wp27
    Participant

    I thought HELOCs were not covered under ATR???

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