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Can you verify that the new escrow rule applies to first lien, HPML, secured by a consumer’s principal dwelling? The distinction that I am making is that escrow would not apply to all HPML’s since a loan secured by a subordinate lien is an HPML if the APR exceeds the APOR by 3.5%, correct?
Under the present rules, and under the revised rules that are effective June 1, 2013, both first lien and subordinate lien transactions may be HPMLs, but the escrow rules only apply to first lien HPMLs secured by the consumer’s principal dwelling. A first lien transaction is a HPML if the the APR exceeds the APOR by 1.5 or more percentage points.
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