The new CFPB calculator is updated accordingly. There is no small servicer exemption for determining HPML status.
New Rate Spread Calculator-APOR Spreadsheet
With the new rate spread calculator, I am wondering if the APOR spreadsheet will it no longer be updated with each Monday? Also, I am getting conflicting answers within the forum: as a small servicer, is there an exception to the threshold of 3.5% on first liens or does the rule apply across the board whether you are a small creditor or not: 1.5% for first lien and 3.5% for subordinate liens to determine the HPML status?
First published on 03/10/2019