On July 30, 2008, the Board of Governors of the Federal Reserve System (“Board”) published in the Federal Register (pages 44522 – 44614) its final rule (the “final rule”) amending Regulation Z and its Official Staff Interpretations in Supplement I to Regulation Z (“Interpretations”). This memorandum will address only that part of the final rule that amends Sections 226.32(d)(7), 226.34(a)(4), and adds new Section 226.35, which relate to HOEPA loans and higher-priced mortgage loans. These amendments become effective October 1, 2009, except for the property tax and insurance escrow requirement of Section 226.35(b)(3) (see page 16 for an explanation).