Yes! Absolutely you can make an HPML without it being a Qualified Mortgage. Manufactured homes without land often have higher rates that simultaneously take them out of QM range and place them squarely in HPML territory. Other higher risk loans might end up in the same place. This is OK, if your loan policy allows for making non-QM (aka ATR) loans. However, there are many additional compliance issues to consider. Tune into the upcoming webinar “Hey HPML! What’s the Matter with QMATR, eh?” on August 5, 2020 to find out exactly what those considerations are, and more!
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Learn more about Rebekah Leonard’s webinar Hey HPML! What’s the Matter with QMATR, eh?