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#2219218 - 08/06/19 07:40 PM Index Rate Change
mdog76 Offline
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Joined: Jan 2007
Posts: 645
What do other banks do if the index used to base rates changes during the underwriting process? Our index dropped putting a loan into HPML which we can't do because we do not escrow. We lowered the rate enough to get under HPML status.

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#2219227 - 08/06/19 07:54 PM Re: Index Rate Change mdog76
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 78,958
Galveston, TX
How does a drop in the index rate make a loan an HPML?
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#2219230 - 08/06/19 07:58 PM Re: Index Rate Change mdog76
mdog76 Offline
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Posts: 645
The rate initially disclosed put us into HPML territory when the index rate dropped.

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#2219238 - 08/06/19 08:24 PM Re: Index Rate Change mdog76
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 78,958
Galveston, TX
Oh - you mean the APOR dropped?
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#2219239 - 08/06/19 08:31 PM Re: Index Rate Change mdog76
mdog76 Offline
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Joined: Jan 2007
Posts: 645
Sorry, wrong terminology but yes.

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#2219367 - 08/08/19 05:51 PM Re: Index Rate Change mdog76
Carolina Blue Offline
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Carolina Blue
Joined: Jul 2005
Posts: 952
Lost in a regulatory fog
If it is your policy to not originate HPMLs then not sure what else you can other than reduce the rate or fees to keep the APR below the threshold.

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