11/01/2010
Reg. Z defines an HPML as "a consumer credit transaction secured by the consumer's principal dwelling with an annual percentage rate that exceeds the average prime offer rate for a comparable transaction as of the date the interest rate is set by 1.5 or more percentage points for loans secured by a first lien on a dwelling, or by 3.5 or more percentage points for loans secured by a subordinate lien on a dwelling". Can a loan with an APR equal to the APOR plus 1.5 or 3.5 (as appropriate) be considered to be an HPML, or must the rate exceed the APOR plus 1.5 or 3.5? Am I over-thinking this?
10/04/2010
In a question that was posed to Patricia Cashman on 7-19-10 concerning HPML and modifications, she stated that escrow will not apply to a true modification. Could she please show me where that can be found in the regulation. I have looked and can't find this. I have this situation and I need more clarification.
09/27/2010
I know loans for the initial construction of a dwelling are exempt from HPML, but does it matter if we know we will be doing the permanent financing when the construction is complete?
08/23/2010
Do the HPML rules apply to renewals of primary occupancy loans that were made prior to the new rules?
03/22/2010
Do the new HPML rules extend to a primary residence offered as collateral by a third party?
03/08/2010
I need clarification on balloon payments. Are we not allowed to have balloon payments on any loan or does it just apply to HOEPA, high rate high fee loans?
02/08/2010
Do non-HMDA reporting banks need to report high cost loans?
01/18/2010
Are Higher Priced Mortgage Loans for loan applications dated on or after Oct 1, 2009? How would you suggest banks handle ARMs that have been on the books prior to 10/01/09? Would these fall into the HPML when these get re-priced?
12/14/2009
The handout for the Reg Z, New Early Disclosures webex indicates on page one that the HPML rules that go into effect on 10/01 do not apply to manufactured housing until 10/01/2010. I need a citation for this, as I can't find anything to back it up. I see where the escrow rules for these loans aren't effective until 10/01/2010, but I'm referring to the income, asset, obligation rules, etc.
12/14/2009
Is HPML triggered when I modify a matured note, meaning there is no new note, no new money and the terms are not changed other than the interest rate?