An HPML and the APR

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?