Our understanding is:
1. For a Non-QM HPCT (HPML) loan use the fully indexed rate
2. For a QM HPCT (HPML) loan use the maximum rate that could apply during the first 5 years after the date of the first payment (so on the 61st month)
3. For a QM Balloon HPCT (HPML) loan have to use the balloon payment which does not factor in the rate
