I am auditing a bank and verifying consumer 1-4 family loans are not HPMLs. I am using the Closing Disclosure date and APR to perform my testing. Am I using the correct date and APR?
Are lot loans exempt from HPML?
What are the HPML rules for a home equity installment loan when the lien for the home equity installment loan is a first lien?
Do we need to test for a mortgage loan being a higher-priced mortgage if it is for a mobile home purchase? It will be the consumer's principal dwelling and no land is being taken as collateral.
Scenario: Consumer purpose balloon loan that was originally the borrower's primary residence and fell into the HPML category. The borrower no longer resides in the property and it is now a rental. Since the purpose has changed from consumer to business, do HPML rules still apply? Can we cancel the escrow account? FYI-we are still within 12 months of origination.
I understand that Reg Z requires us to set up an escrow account for loans that qualify for HPML. If the security is made up of separate tracts of land and only one of the tracts includes the first lien on a principal dwelling are we required to escrow for taxes and insurance on the other tracts of land?
Are there any available cures if an HPML is closed without escrow?
What if an HPML calculation was done incorrectly, later discovered to be an HMPL, and the first-mortgage loan closed without escrow? Is there a remedy?
Are there additional disclosures required if a lender does choose to close an HPML loan when the loan fails HPML but passes Section 32?
Our software company recently changed the TL Statement on HPML Real Estate Loans to disclose a maximum payment amount on Variable Rate Real Estate Loans (maximum during first five years). We understood that the Debt to Income Ratio on these Loans were to be based upon the maximum during the first 7 years after consummation. Please Help.