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Verifying mortgages for HPML status

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Question: 
I am auditing a bank and verifying consumer 1-4 family loans are not HPMLs. I am using the Closing Disclosure date and APR to perform my testing. Am I using the correct date and APR?
Answer: 

You need to be using the last date on which the rate was set.

1026.35(a) Definitions. For purposes of this section:

(1) "Higher-priced mortgage loan" means a closed-end consumer credit transaction secured by the consumer's principal dwelling with an annual percentage rate that exceeds the average prime offer rate for a comparable transaction as of the date the interest rate is set:

First published on 04/09/2017

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