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Lot Loans and HPML

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Question: 
Are lot loans exempt from HPML?
Answer: 

The definition of "higher-priced mortgage loan (HPML) starts section 1026.35(a) of Regulation Z:

"(1) "Higher-priced mortgage loan" means a closed-end consumer credit transaction secured by the consumer's principal dwelling ...."

A lot loan does not include a dwelling. Therefore it cannot be an HPML.

Definitions are the skeleton on which all the rest of Regulation Z is hung.

First published on 09/18/2016

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