I am looking for information on doing a HPML for a jumbo. We have never done one in the past and this will most likely be a one-off. It will be north of 950M so it is solid in the jumbo category. The information I found on ConsumerFinance.gov
indicates a jumbo is considered HPML once it is 2.5% or more over APOR. Yet in reading our state bankers association real estate lending manual, it does not reference any difference between jumbo or standard and shows 1.5% or more for first lien and 3.5% or more for subordinate liens. Those of you who write jumbo HPMLs, what has been your practice? Also, what is the maximum you generally cap your percentage at? I do not want to give free rein for this to be abusive. Is there a percentage cap for the fees that is specific to jumbos? Again, we have never done one of these and I'm struggling to find concise information on the requirements we need to be mindful of - I really appreciate any help you all may have!