Recent Changes to HOEPA

In Brief

• The CFPB issued a final rule amending Regulation Z by expanding the types of transactions subject to the HOEPA, revising and expanding HOEPA thresholds, and imposing additional requirements on HOEPA loans.
• The final rule will increase the number of loans subject to HOEPA, and the new and lower thresholds will increase the number of loans classified as high-cost mortgages.
• It remains to be seen whether the rule will reduce access to credit or help consumers.