I just wanted to clarify this by bouncing off BOL:

HPMLs do NOT include second or vacation homes - only primary dwelling. Correct???

My understanding it covered second homes per the Mortgage Disclosure Improvement Act.

Primary Dwellings only.

Thanks - just to clarify:

The MDIA applies to second/vacation homes for ETIL and the 7/3 day rules....

but the HPML test would NOT apply to second/vacation homes.

Correct???

226.35

(a) Higher-priced mortgage loans--(1) For purposes of this section, a higher-priced mortgage loan is a consumer credit transaction secured by the consumer's principal dwelling with an annual percentage rate that exceeds the average prime offer rate for a comparable transaction as of the date the interest rate is set by 1.5 or more percentage points for loans secured by a first lien on a dwelling, or by 3.5 or more percentage points for loans secured by a subordinate lien on a dwelling.

Correct. Don't forget the rate spread reporting under Reg. C. If you have a HMDA-covered application you would have to report a rate spread. The definition of dwelling under Reg. C includes second homes.