In January 2013, the Consumer Financial Protection Bureau issued a rule (referred to throughout this guide as the “2013 HOEPA Rule”) that amends TILA’s Regulation Z to implement the Dodd-Frank Act’s changes to HOEPA.
The 2013 HOEPA Rule also implements two additional Dodd-Frank counseling requirements that may apply to creditors regardless of whether or not they make high-cost mortgages. Specifically, these provisions require or encourage consumers to obtain homeownership counseling for other types of loans. Users of this guide should keep in mind that these homeownership counseling-related requirements are not amendments to HOEPA, but are separate amendments to the Real Estate Settlement Procedures Act ’s (RESPA’s) Regulation X and the Truth in Lending Act ’s (TILA’s) Regulation Z that apply to different types of transactions. These requirements are covered separately in Part 5 of this guide.