Is the “Finance Charge and the Total of points and Fees Calculator” given to us a couple of meetings ago, to be used for ATR as well as the new HOEPA calculations? I had in my notes for HOEPA that you use the same determination for points and fees as you would for ATR so I am assuming this calculator would work for both?
Also, when is the CFPB supposed to have their lists of homeownership counselors available?
Yes, see in the ATR rules below that it references the high cost mortgage points and fees test. 1026.43(e)(3): Limits on points and fees for qualified mortgages. (i) A covered transaction is not a qualified mortgage unless the transaction’s total points and fees, as defined in § 1026.32(b)(1), do not exceed…
And I haven’t heard anything on the CFPBs list of homeownership counselors. Let’s hope they have it available by the effective date of January 10th.