Hi everyone, I thought I had read that if a HPML the only ones that had to complete counseling is if they were a first time homebuyer. Is this true, or is it any HPML if first time homebuyer or not?

There isn't a counseling requirement specific to HPMLs.

The counseling requirement is for High Cost (HCML/Section 32/HOEPA) loans OR any closed end residential loan to a first time borrower with negative amortization (except reverse mortgages).

We dont have any negative amoritization loans. So if we have a High Cost no matter if a first time home buyer or not, if it's high cost then they need to complete the counseling?

1026.34

(5) Pre-loan counseling. (i) Certification of counseling required. A creditor shall not extend a high-cost mortgage to a consumer unless the creditor receives written certification that the consumer has obtained counseling on the advisability of the mortgage from a counselor that is approved to provide such counseling by the Secretary of the U.S. Department of Housing and Urban Development or, if permitted by the Secretary, by a State housing finance authority.

Thank you both for your help.