HPML and Modication Due to Pandemic

Home » Topics » Pandemic Related Issues » HPML and Modication Due to Pandemic

This topic has 1 reply, 1 voice, and was last updated 5 years, 7 months ago by rcooper.

Creator

Topic
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?
Creator

Topic

Viewing 1 replies (of 1 total)

Author

Replies
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.
Author

Replies

Viewing 1 replies (of 1 total)

You must be logged in to reply to this topic.