HPML and Renewal

Posted By: Sugarbaker

HPML and Renewal - 09/26/11 06:56 PM

Do we need to run the FFIEC HPML calculation for renewals? I'm thinking yes, but want to make sure I'm not missing an exemption.

Thanks.
Posted By: rlcarey

Re: HPML and Renewal - 09/27/11 12:21 AM

Either you are dealing with a refinancing or not. If a refinancing, then all HPML and other Regulation Z requirements apply.