Additional Disclosures for Closing HPML Loan?

Answered by:

Question:

Are there additional disclosures required if a lender does choose to close an HPML loan when the loan fails HPML but passes Section 32?

Answer:

Answer from Dan: There are no additional disclosures connected to loans subject to the 1026.35 requirements.

Answer:

Answer from Andy: A caveat to Dan's answer is that you would review 1026.35 as there are some things that can't be included in your documents or are conditioned, such as prepayment penalty fees, and you may have new dislosures related to escrows. So there are special requirements pertaining to HPMLs, but not disclosures stating this is an HPML.

First published on BankersOnline.com 4/16/12