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#2172923 - 04/11/18 01:15 PM HPML - Bridge Loan
mdog76 Offline
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Just wanting to make sure a bridge loan is not subject to HPML. I see where its not required for escrow, but what I'm reading doesn't exactly say that its exempt from HMPL

Thank You.

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Lending Compliance
#2172941 - 04/11/18 01:45 PM Re: HPML - Bridge Loan mdog76
Adam Witmer Offline
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1026.35 has separate exemptions for each part of the rule.

1026.35(b)(2)(C) exempts bridge loans from the escrow rules:
(C) A temporary or "bridge" loan with a loan term of twelve months or less, such as a loan to purchase a new dwelling where the consumer plans to sell a current dwelling within twelve months; or

1026.35(c)(2)(v) exempts bridge loans from the appraisal rules:
(v) A loan with maturity of 12 months or less, if the purpose of the loan is a “bridge” loan connected with the acquisition of a dwelling intended to become the consumer's principal dwelling.
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#2172944 - 04/11/18 01:48 PM Re: HPML - Bridge Loan mdog76
mdog76 Offline
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So we are safe in saying that if its exempt from each part its exempt from the whole thing? Just want to make sure.

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#2172957 - 04/11/18 02:19 PM Re: HPML - Bridge Loan mdog76
rlcarey Offline
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Being exempt from the escrow and appraisal rules does not turn the loan into a non-HPML.
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#2172963 - 04/11/18 02:45 PM Re: HPML - Bridge Loan mdog76
Adam Witmer Offline
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Originally Posted By rlcarey
Being exempt from the escrow and appraisal rules does not turn the loan into a non-HPML.
Put another way, it is still considered an HPML but is exempt from the escrow and appraisal requirements. Basically, the way the rule is written you can't say it is a non-HPML.
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Adam Witmer, CRCM

All statements are my opinion, not those of my employer, and should not be taken as legal advice.
www.compliancecohort.com

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#2172964 - 04/11/18 02:52 PM Re: HPML - Bridge Loan mdog76
rlcarey Offline
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Galveston, TX
i.e. if it a HPML and has a balloon payment, ATR is calculated differently, even if it is exempt from the escrow and appraisal requirements.
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#2172966 - 04/11/18 03:00 PM Re: HPML - Bridge Loan mdog76
Adam Witmer Offline
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Exactly. Same for HMDA..... IF there is a scenario where the loan would be reportable.
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Adam Witmer, CRCM

All statements are my opinion, not those of my employer, and should not be taken as legal advice.
www.compliancecohort.com

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#2172972 - 04/11/18 03:22 PM Re: HPML - Bridge Loan Adam Witmer
RR Joker Offline
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Originally Posted By Adam Witmer
Exactly. Same for HMDA..... IF there is a scenario where the loan would be reportable.


This doesn't really mean anything anymore as all spreads [if any] are now reported wink
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#2172973 - 04/11/18 03:26 PM Re: HPML - Bridge Loan mdog76
mdog76 Offline
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Just so I am straight with this:
We are not a HMDA reporting Bank, the bridge loan would still be considered HPML but exempt from escrow and appraisal rules. So then what if any disclosures would be required?

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#2173025 - 04/11/18 05:43 PM Re: HPML - Bridge Loan mdog76
rlcarey Offline
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Galveston, TX
There are no special disclosures for an HPML loan, it impacts underwriting, appraisals and escrows.
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#2173044 - 04/11/18 06:29 PM Re: HPML - Bridge Loan mdog76
mdog76 Offline
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Posts: 645
Ok. Thank you all for the help.

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