Our lenders are given rate guidelines (can't deviate). HPML spreads are not an issue with our lenders. Since the HPML is based on the APR, rather than the loan rate, there's really no way for the lender to know if the loan has hit the HPML trigger or not.....and we're not tryng to avoid HPML. If a loan hits the trigger, it does. We already verify borrower's ability to repay with documentary proof....we already give weight to "mortgage obligations" with respect to the borrower's ability to repay. The only change we've made is that we no longer offer a 5-year balloon term...period. If a balloon loan is desired, seven years is the minimum and is generally our standard product. Then the HPML is reported on the HMDA Lar.
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The more you sweat in training, the less you bleed in battle.......