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Originally posted in Compliance Masters Group Forum by wp27:
Since the requirements in 1026.35(e) regarding ability to repay for HPMLs expired on January 9, do we just refer to the new ability to repay rules now? For example, if we are using the Small Creditor QM, does that cover us for the HPML ability to repay/prepayment penalty requirements now?
Yes, you are now determining ability to repay in compliance with the 1026.43 requirements rather than the 1026.35(e) requirements since they have expired.
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