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Reply To: HOEPA vs. HPML vs. HPCT

#4070
rcooper
Member

Yes, if you have an HPCT QM it determines that you only get the rebuttable presumption of compliance rather than the safe harbor. Also if you have a non-QM balloon loan that is a HPCT you have to factor in the balloon payment into the payment calculation (see 1026.43(c)(5)(ii)).