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!

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.

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.