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HMPLs - Initial Rate Set for 4 Years?

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Question: 
Am I correct in understanding that with a variable rate real estate loan subject to the higher priced mortgage loans effective 10/01/09 under 226.32(b)iv, the initial rate cannot change until after four years?
Answer: 

You need to refer to 226.35 for HPMLs. 226.32 refers to HOEPA loans.

First published on BankersOnline.com 2/15/10

First published on 02/15/2010

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