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If a bank makes a HPML and fails to escrow, can the violation be cured by lowering the rate on the loan to level that would not be a HPML?
You can not cure the violation. Be glad that you caught it and not an examiner. Now that you know about it, take the opportunity to determine the root cause of the error and take corrective action to prevent it going forward. Typically examiners will give you a little slack if you find the issue on your own and take corrective action to ensure it doesn’t happen again. Lowering the rate would show an effort fix the issue and may help mitigate action taken by examiners, but it will not cure the original violation.
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