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HPML and Modication Due to Pandemic

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  • March 31, 2020 at 12:59 pm EDT #31923
    rcooper
    Member

    Question from our recent webinar, Pandemic Relief – Managing Compliance Issues:
    Are you required to re-check HPML requirements on modifications if HPML was established when the loan was originated?

    March 31, 2020 at 12:59 pm EDT #31924
    rcooper
    Member

    The HPML rules apply when you extend credit (i.e. new transactions). If you have a “refinancing” under 1026.20 that would be considered a new transaction, however, a modification would not.

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