We price our loans based on the "calculator" because we are not set up to service HPML loans and provide the periodic statements. With that said, here is our question:

We made a loan 5/1 ARM loan August 2014 with a rate below the calculator rate. We have since discovered that at time of first rate change in August 2019, its looking like the rate change will put us over the rate for HPML loans. What's the best option to handle this situation?

HPML calculations are based on the effective rate and fees at the time of closing. Future rate adjustments are not a factor.

HPML is also based on the APR, which while related, really has nothing directly to do with the interest rate on the loan.

So we should be good then. Thanks for the help.