Outside of the additional exception for a jumbo loan, there are no specific small creditor exceptions on rates when determining HPML coverage. Don't confuse HPML with QM guidelines.
HPML Threshold for Rate Spread (Reg Z)
It is my understanding that the HPML threshold for the rate spread is the same across the board; 1.5% for first liens and 3.5% for subordinate liens. As a small creditor, is there an exception that applies, making our threshold 3.5% regardless of lien position? I found this in one of the answers within a forum and don't want to misinterpret it: "As for the threshold for determining a higher-priced covered transaction, small creditors are unique in that they receive the 3.5% threshold for first lien small creditor and balloon payment QM's."
First published on 03/18/2018