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WASHINGTON-In a recent letter to Senate Banking Committee Chairman Paul Sarbanes (D-Md.), CUNA expressed its support for the Predatory Lending Consumer Protection Act of 2002 (S. 2438). The purpose of the bill is to amend the Home Ownership Equity Protection Act (HOEPA) to address predatory lending practices. HOEPA sets disclosure requirements for loans with interest rates, points, and/or fees above certain thresholds. Sarbanes’ legislation will lower those thresholds to six percentage points above comparable Treasury securities for first mortgages and eight percentage points above comparable Treasury securities for second mortgages. Additionally, HOEPA will apply when points and fees exceed the greater of 5% of the total loan or $1,000. Currently, the law reads 8% of the loan amount or $480. CUNA wrote in support of these lower thresholds, as well as other provisions of the bill including: *

prohibiting creditors from financing points, fees or other fees greater than 3% of the total loan or $600; *

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