Just taking a shot here, but i would think the issue would be if you have an HPML that you didn't treat as an HPML. So, and this is just me, i would be worried if these loans weren't being tested for HPML status not because of a lack of calculation being there for audit purposes, but because of the ramifications if a loan closed as an HPML and the repayment, verification of debt/income, escrow, etc. hadn't been performed. I guess i'm saying i don't see an auditor looking in a file, not seeing any HPML test done, testing it themselves, and finding out it isn't an HPML as nearly a big a deal as if the loan closed as an HPML and nobody bothered to test for it and now what? If you are talking about testing the rate spread to see if it qualifies, are you saying the rate spread isn't being done or isn't being kept with the file? Just my 2 cents worth, and i hope i understood what you were asking.
Last edited by raitchjay; 03/10/11 08:21 PM.
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I'm fixin' to fix that.