In the more than 28 years that J. L. Sherman & Associates has been providing lending calculation solutions, keeping our partners in compliance with Truth in Lending has always been a given. In the past, the primary compliance focus was on the disclosure of the APR and other elements that make up the “Federal Box”. However, in recent years we have witnessed a dramatic increase in new federal regulations. First came the Home Ownership and Equity Protection Act (HOEPA), then the Higher Price Mortgage Loans rule became effective in 2009, then HOEPA was revised for 2013, and now the new TILA RESPA rules which go into effect this August of 2015.

The CFPB is adjusting two dollar amounts that are used in the “points and fees” trigger for coverage under HOEPA. The two dollar amounts are (1) the loan amount threshold (changing from $20,000 to $20,391), and (2) the total points and fees amount (changing from $1,000 to $1,020). All of our core products have been updated to include these new amounts, ensuring that your organization is compliant with the new year’s values.

Just over a year ago, we published an article entitled APR Calculation Software for PayDay Lenders. This article discusses the allowed 1/8% APR disclosure tolerance, and how dangerously easy it is to violate this Federal restriction, when the APR is in the hundreds of one percent. Finally, the article introduces our APR compliance software as a complete solution to this critical, highly sensitive, and difficult calculation.

The Home Ownership and Equity Protection Act (HOEPA) was enacted in 1994 as an amendment to the Truth in Lending Act (TILA) to address abusive practices in refinances and closed-end home equity loans with high interest rates or high fees. Mortgage loans which fall under HOEPA (hereafter called High Cost Mortgages, or HCMs) are subject to special disclosure requirements and restrictions. Since the very early days of the Sherman Calculation Engine with XML interface (SCEX) (circa 2002), J. L. Sherman and Associates has provided functionality to check if a given loan falls under the HOEPA regulation, and it is used by many of our partners today.

We are happy to announce that Cash Time Loan Centers has selected J. L. Sherman & Associates as their exclusive partner for loan calculations within their loan origination system. Cash Time is using the Sherman Calculation Engine with XML Interface (SCEX) to drive the calculations within their new system.