Compliance Blog

Aug 21, 2009

HOEPA - Sections 226.17 .19; This and that

Posted by Anthony Demangone

I'll handle these two sections rather quickly.  As I mentioned earlier, the Fed first issued their HOEPA regulations in 2008.  But then Congress passed MDIA, which overtook the HOEPA regs in several areas.  Well, the overlapped areas affect the two sections noted above in this post's title.

Sections 226.17 (general disclosure requirements) and .19 (certain mortgage and variable rate transactions) were amended by the Fed in 2008, but were superseded by the MDIA amendments to Reg Z.  When you begin working toward compliance for HOEPA, remember this important distinction.  The FDIC created thisgreat side-by-side chart that details how MDIA widened and strengthened the disclosure requirements.

With all the important compliance work we're going to have to do, I didn't want you heading down alleyways that are no longer relevant.

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Here are a few things kicking around my in-box.

Have a great weekend, everyone.