Legal Bulletins
HOEPA Trigger Rates
Effective January 10, 2014, new federal regulations change the measure and method for determining if the Annual Percentage Rate makes a consumer home loan subject to the Truth-in-Lending Act HOEPA requirements. See 12 CFR ยง1026.32. (The regulations also expand the types of loans that may be subject to HOEPA and change what "points and fees" make a loan subject to HOEPA.) In light of these changes, there is no need to continue publishing our monthly HOEPA Trigger Rates chart, with one exception.
The new regulations become effective January 10, 2014. Thus, for loan applications received between January 1 and January 9, 2014, the "old" trigger rates apply.
We thank you for your loyalty throughout the years, and for one last time provide the following.
What are "trigger" rates for loan applications received by lender between January 1 and January 9, 2014?
Look to U.S. Treasury yields for December 13, 2013. Compare these yields to the APR on the loan. (Note: when the loan closes is not a measuring date.) Loan is covered by HOEPA if APR at consummation exceeds the trigger rate.
| Loan Maturity | U.S. Treasury Yield on | Trigger APR for 1st Liens | Trigger APR for 2nd Liens |
| 1- Year | 0.14% | Above 8.14% | Above 10.14% |
| 2-Year | 0.34% | Above 8.34% | Above 10.34% |
| 3-Year | 0.68% | Above 8.68% | Above 10.68% |
| 5-Year | 1.55% | Above 9.55% | Above 11.55% |
| 7-Year | 2.25% | Above 10.25% | Above 12.25% |
| 10-Year | 2.88% | Above 10.88% | Above 12.88% |
| 20-Year | 3.61% | Above 11.61% | Above 13.61% |
| 30-Year | 3.88% | Above 11.88% | Above 13.88% |