What APOR Index Date to Determine HPML

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Question:

Assuming your interest rate is locked at application and your initial APR is below HPML trigger, if loan fees change causing the closing APR to increase (no change in rate) what APOR index date do you use to determine if you have an HPML? I understood it to be the date the rate is locked or set, but now I'm hearing you also have to verify the closing APR to see if you have a HPML?

Answer:

Determining the HPML threshold is based on the APOR on the date the rate was set. The APR that you compare to the APOR always comes from your final TIL disclosure and not your early disclosures.

First published on BankersOnline.com 6/3/13