Answer:
Yes, this is not a construction only loan; therefore, it is not exempt from HPML requirements.
First published on BankersOnline.com 1/25/10
Subject to HPML Requirements?
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Question:
Regarding the new Reg Z amendment that added section 35 for HPMLs, are one-time close construction loans that have interest only payments during construction and then convert to permanent financing upon completion, subject to the HPML requirements?
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