They have slightly different thresholds. The big difference is HPML is principal dwelling secured and HPCT is dwelling secured. In addition, there is an additional threshold for jumbo HPMLs. So, just because one applies won’t always mean that both apply.
Higher Priced Mortgage Loan (HPML)
Closed end consumer credit secured by a principal dwelling with APR that exceeds the APOR by:
• 1.5% or more – first lien
• 2.5% or more – first lien jumbo
• 3.5% or more – subordinate lien
Higher Priced Covered Transaction (HPCT) 12 CFR 1026.43(b)(4):
Consumer credit secured by a dwelling with APR that exceeds the APOR by:
• 1.5% or more – first lien loans
• 3.5% or more – subordinate lien loans