Subject to HPML Requirements?
Answer by David Dickinson, BOL Gurus Guru Bio
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?
Answer: Yes, this is not a construction only loan; therefore, it is not exempt from HPML requirements.
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