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HPML Threshold for Rate Spread (Reg Z)

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Question: 
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."
Answer: 

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.

First published on 03/18/2018

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