Determining whether or not a loan is a HPML under Section 35 has nothing to do with a QM determination under Section 43.
New HPML Rules Defined
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?
First published on 12/04/2022