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#1374861 - 04/15/10 07:18 PM HPML/Rate spread
#12 Offline
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Joined: Jun 2005
Posts: 1,338
Brain freeze, need some help! 1st lien loan to a borrower on a 2nd home. The rate spread indicates that it would be a HPML, but since it is a 2nd home, the HPML rules would not apply, correct?

Would we still report the rate spread on the LAR? I think yes, but would like confirmation.

Thanks in advance!
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#1374871 - 04/15/10 07:29 PM Re: HPML/Rate spread #12
Dan Persfull Offline
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Dan Persfull
Joined: Aug 2002
Posts: 46,762
Bloomington, IN
HPML applies to the primary residence, you are still required to report a rate spread on the LAR if the loan is subject to Reg Z disclosures.
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#1374872 - 04/15/10 07:32 PM Re: HPML/Rate spread Dan Persfull
#12 Offline
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Joined: Jun 2005
Posts: 1,338
Thank you Dan. Something I read in a training manual was throwing me off, but I couldn't find anything in Reg C that told me not to report it.

Have a great afternoon.
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