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!