New HPML Rules Defined

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Question:

Under the new QM/ATR rules that take effect on Oct 1, 2022, when does a loan become HPML? Is it still based on the 1.5%-1st lien, 3.5%-2nd lien, or does it now go by the new thresholds in the price-based tiers, for instance, 1st lien is less than $68,908 has a 6.5% threshold between the APR & APOR?

Answer:

Determining whether or not a loan is a HPML under Section 35 has nothing to do with a QM determination under Section 43.