Richard,
Those are ones that I am talking about. While Appendix D remains - which allows you to split the transaction for TIL disclosure purposes, the newer HPML rules trigger when the APR exceeds a specific threshold. Which APR do you use if you have two?? The same applies for reporting the APR rate spread for HMDA - which one do you use? There is no guidance in either regulation that addresses this.
It is once again a situation where the complexity of the regulations have outstripped its own complexity
So, divide and conquer from a reimbursement status and get cited for two unrelated violations??