[avolentine]

Robin,

We meet the definition of small creditor and we are confused about HPCT and HPML. Are principal dwellings AND all other dwellings covered under HPCT?

For example, we have a 1st lien primary residence loan that is a Small Creditor QM priced at 5.0% when the APOR is 2.90% so we have priced it 2.10% over the APOR. Does this make it a HPML but not a HPCT? If so is the only requirement that we would have to escrow? (We aren’t exempt from the Small Servicer Escrow Rules as we were escrowing prior to 1/13).

Thank you!

[avolentine]

I should have worded my question differently, if we have escrowed on loans that are not HPMLs, does this require us to continue to escrow or can we still meet the exemption requirements?

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