HPML & HCM Questions
Do you have questions related to Higher-Priced and/or Higher-Cost Mortgage Loans? You are not alone! Here are some questions we’ve received:
Question: If we change the rate on a consumer loan that is subject to the Higher-Priced Mortgage Loan (HPML) or High-Cost Mortgage (HCM) requirements, do we need to verify if the new rate will make the loan an HPML or HCM?
Answer: The only time you would need to go back and re-check the rate and/or points and fees is if you are refinancing the loan or making a new loan (i.e., note).
Question: If we currently escrow for a non-HPML loan, will we lose our small creditor exemption status?
Answer: To qualify for the Small Creditor exemption, you can’t have any escrow accounts other than those established for an HPML application received on or after April 1, 2010 and prior to June 17, 2021. If you have an escrow account for a non-HPML, you don’t qualify for the exemption, unless the account was created to help a distressed borrower avoid foreclosure.
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Published
2021/04/19
Amy Kudlacek
Amy brings many years of banking and compliance experience to Banker’s Compliance Consulting. She has worked for both large and small financial institutions and spent time working in every area of a bank. She started out as a teller in college and eventually became a branch manager. Her love, however, was always compliance. Amy began her career with Banker’s Compliance Consulting in 2000. Her knowledge and experiences have allowed her to develop a well-rounded and practical approach to regulatory compliance. Amy is CRCM certified, has a Bachelors Degree in Business Administration and is a graduate of the ABA Compliance School. Amy & her husband have two children at home and stay busy following their activities. They spend a lot of time in the bleachers!