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Tag: HOEPA

1 article tagged “HOEPA”
Compliance

The Points-and-Fees Test Runs at Pricing, Not at Closing: HOEPA High-Cost Coverage and the QM Cap With an AI Agent

Two separate points-and-fees calculations decide whether a mortgage is a high-cost loan under HOEPA and whether it keeps its Qualified Mortgage status. Both run off the same fee total, both have coverage lines a single late fee can cross, and both are cheapest to check while the loan can still be repriced. What counts as a point or fee under Reg Z 1026.32, why the test belongs at pricing, and where an AI agent flags the breach before the loan is locked into it.

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