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The 2015 legislation amending the High Risk Home Loan Act (P.A. 99-288) states that it takes effect upon becoming law, and it became law on August 5, 2015. Does it apply only to loan applications received on or after August 5, 2015, or does it also apply to loans closed on or after August 5, 2015, for which applications were received before August 5, 2015? – IBA Compliance Connection

IBA Compliance Connection

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The 2015 legislation amending the High Risk Home Loan Act (P.A. 99-288) states that it takes effect upon becoming law, and it became law on August 5, 2015. Does it apply only to loan applications received on or after August 5, 2015, or does it also apply to loans closed on or after August 5, 2015, for which applications were received before August 5, 2015?

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Changes made by Public Act 99-288 to the High Risk Home Loan Act apply to all “high risk home loans” closed on or after August 5th. The definition of “high risk home loan” in Section 10, which is what the legislation amended, is tied to the qualifying clause “at the time of origination.”

For resources related to our guidance, please see:

  • Public Act 99-288 (A “High risk home loan” means a home equity loan in which (i) at the time of origination . . . .”)