Under the new QM/ATR rules that take effect on Oct 1, 2022, when does a loan become HPML? Is it still based on the 1.5%-1st lien, 3.5%-2nd lien, or does it now go by the new thresholds in the price-based tiers, for instance, 1st lien is less than $68,908 has a 6.5% threshold between the APR & APOR?
Does flood insurance need to be in effect the day before a loan closes or the day of is sufficient?
We have a HELOC that is going to pay off a tax lien on a dwelling. Should the purpose be reported as "Refinance" or "Other" for HMDA purposes?
What are the potential benefits of automated exception reports?
Will section 1071 rules be covered in the program?