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HPML requirements

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  • January 21, 2014 at 9:01 am EST #5023
    Anonymous
    Inactive

    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?

    January 21, 2014 at 10:17 pm EST #5030
    rcooper
    Member

    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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