Question specifically about Jumbos.
The price based QM rule considers a loan where the APR exceeds the APOR by 1.5% a rebuttable presumption QM (i.e. HPML), When the APR exceeds the APOR by > 2.25% (1026.43 (e)(2)) , the loan is non-QM.
The HPML escrow rule requires creditors to establish an escrow account on HPML loans. HPML is defined in Reg Z as when a the APR exceeds the APOR by 2.5 points on a jumbo loan. (1026.35). I am trying to reconcile the test for QM HPML under 1026.43 and test for HPML escrow rule under 1026.35. It seems as if on a jumbo loan, it is possible to have the loan be non-qm under 1026.43 but not HPML under 1026.35. For ex: APR exceeds APOR by 2.30. The jumbo loan would be non-QM under 1026.43 but not HPML under 1026.35?
Am I understanding this correctly?
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