Reviews

Baseline Reviews

• TILA
• HOEPA & High Costs
• Broker & Lender Licensing
• State Consumer Credit
• HMDA
• CRA^X
• OFAC/SSN

• Lender Profile
• Client Position Rules
• Custom Enterprise Rules

• Fannie Mae Requirements
• Other Investor Requirements

HOEPA, State and Local High Costs

Federal (HOEPA), State and Local High Cost Thresholds

Mavent compares the loan data to the calculated high cost thresholds as defined in the Home Ownership and Equity Protection Act (HOEPA) and applicable state and local jurisdictions.

Mavent does not require the client to make any determination about whether a fee is a Finance Charge or is included in a points and fee analysis. In other words, clients do not submit calculated values (e.g. Total Loan Amount) or Finance Charge "flags." Using raw loan data, Mavent recalculates all values and classifies all fees to determine whether an APR or points and fees threshold has been triggered. (Client Position Rules allow clients to direct Mavent to formally override a fee classification or other compliance rule based on the client's differing regulatory interpretation.)

Mavent returns exception messages showing the calculated loan APR and points and fees versus the legal limits (including the difference). Mavent also returns payment streams, Finance Charge worksheets, and high cost points and fees worksheets to assist the client in curing potential high cost loans.

First Pass™

Mavent can also perform a First Pass™—or "worst-case"—review for clients that do not have access to all loan data in electronic format, such as secondary market investors. First Pass™ uses a smaller set of gross fee data to determine which loans in a universe are at significant risk of violating an applicable high cost law. Those loans identified can be re-submitted with more detailed fee data to determine whether they are indeed high cost loans.