Answer:
HPML requirements and restrictions apply to the APR at consummation. Rate adjustments in accordance with properly disclosed variable rate terms are not affected.
First published on BankersOnline.com 11/01/10
Avoiding HPMLs
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Question:
At this time, we are trying to avoid HPMLs by keeping our rates within the tolerance threshold. I am assuming that when it comes time for a rate to adjust, such as in the case of an ARM loan, we need to make sure the rate continues to fall within the HPML limits based on the rates at the time of the adjustment. Is this correct?
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