HPML Trigger

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Question:

Is HPML triggered when I modify a matured note, meaning there is no new note, no new money and the terms are not changed other than the interest rate?

Answer:

No. However, how can you modify a loan that has already matured?

If you renew/extend/modify a loan before maturity, you do not trigger the HPML rules, as there is no new APR (no new TIL disclosures) to compare to the APOR.

First published on BankersOnline.com 12/14/09