How do you explain HPML to a borrower?

Asked by: Colt Emard  |  Last update: October 25, 2025
Score: 4.2/5 (13 votes)

A higher-priced mortgage loan (HPML) is a mortgage with an annual percentage rate (APR) that's higher than the average prime offer rate (APOR) offered to well-qualified borrowers.

Which one of the following best describes an HPML?

HPML. High-Priced Mortgage Loans (HPML) are the ones that have high prices of interests, closures of loans, and monthly installments which, stand higher than the Average Prime Offer Rate (APOR) in the market. They are consumers having difficulty in finding dwelling loans.

What causes a loan to be HPML?

Your mortgage will be considered a higher-priced mortgage loan (HPML) if the APR is a certain percentage higher than the APOR, depending on what type of loan you have: First-lien mortgages: If your mortgage is a first-lien mortgage, the lender of this mortgage will be the first to be paid if you go into foreclosure.

What are two requirements for higher-priced mortgage loans HPMLs?

HPML/Section 35 Loan Definition

Regulation Z defines an HPML as a mortgage secured by a borrower's principal dwelling with an APR that is at least 1.5% higher (for a first lien) or at least 3.5% higher (for a second lien) than the average prime offer rate (APOR) for a comparable transaction as of the rate lock date.

How to figure HPML?

For first liens, add 1.5 % to the listed index if the loan was locked in (or re-locked) during the week following the date. For example, if your APR is 7.09 and you subtract 1.5 your answer is 5.59. If your answer is higher than the posted index, which is currently 5.09 your loan is classified as an HPML.

HPMLs - Higher Priced & Higher Cost Mortgage Loans

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How to avoid HPML?

There are five key ways to avoid an HPML loan:
  1. Don't take out an FHA loan.
  2. Boost your credit scores so you qualify for a conventional loan.
  3. Make a bigger down payment.
  4. Ask the seller to pay closing costs.
  5. Buy a site-built home.

Do HPML require two appraisals?

If the consumer is applying for an HPML to buy a flipped property, an additional appraisal is required if the price reflected in the consumer's purchase agreement is a certain amount higher than the seller's acquisition price.

What types of loans are excluded from HPML?

The HPML Appraisal Rule exempts the following loans from all of its requirements:
  • Qualified Mortgages, as defined in Regulation Z (12 CFR § 1026.43(e)) and the CFPB's Ability-to-Repay/Qualified Mortgage Rule; ...
  • Reverse mortgages;

Which of the following is not a characteristic of an HPML?

The answer is it has an APR that exceeds the rate for Treasury securities with a comparable rate of maturity by 6.5 percentage points. Having an APR that exceeds the rate for Treasury securities with a comparable rate of maturity by 6.5 percentage points is not a characteristic of an HPML.

What determines a high-cost mortgage loan?

High-cost mortgages include closed- and open-end consumer credit transactions secured by the consumer's principal dwelling with an annual percentage rate that exceeds the average prime offer rate for a comparable transaction as of the date the interest rate is set by the specified amount.

Does HPML require escrow?

Generally, under the rule, when a creditor originates a HPML secured by a first lien on a principal dwelling, the creditor must establish and maintain a mandatory escrow account until one of the following occurs: 1) the underlying debt obligation is terminated or 2) after five years elapses from the date the loan was ...

What does high interest rates mean for borrowers?

Higher interest rates mean higher payments on many mortgages and loans, meaning people must spend more on them and less on other things. It also means savers get more return and potential borrowers find it is more expensive to take out a loan.

What is the HPML loan amount threshold for 2024?

For 2024, the institution may use an alternative method of valuation (and not obtain a full appraisal) in connection with an HPML of $32,400 or less. This is up from the current level of $31,000 for 2023. The final rule is available here.

How do you explain HPML?

A First Lien Mortgage secured by a Primary Residence that has an annual percentage rate (APR) of 1.5% or more above the average prime offer rate (APOR) for a comparable transaction as of the rate lock date.

Which threshold are HPMLs identified using?

From January 1, 2022, through December 31, 2022, the threshold amount is $28,500. 4. Qualifying for exemption—in general. A transaction is exempt under §34.203(b)(2) if the creditor makes an extension of credit at consummation that is equal to or below the threshold amount in effect at the time of consummation.

Which of the following best describes a balloon mortgage?

A balloon mortgage is a real estate loan with an initial period of low or no monthly payments. The borrower pays off the full balance in a lump sum at the end of the term.

What is the HPML rule for FHA loans?

HPMLs are loans secured by consumer's principal dwelling with an annual percentage rate (APR) exceeding the average prime offer rate (APOR)1 by: 1.5% or more on first lien mortgage which is a non-jumbo, non-FHA loan. 2.5% or more on first lien mortgage which is a jumbo loan. 3.5% on loans secured by second lien.

What is Jumbo debt?

A loan is considered jumbo if it exceeds the maximum loan limits for Fannie Mae and Freddie Mac conforming loans—currently $766,550 for single-family homes in most parts of the U.S. but up to $1,149,825 in certain more expensive areas.

Which is a prohibited practice involving a high cost mortgage?

(vi) Steering prohibited.

A creditor that extends a high-cost mortgage shall not steer or otherwise direct a consumer to choose a particular counselor or counseling organization for the counseling required under this paragraph (a)(5).

When must the loan estimate be provided to the borrower?

A Loan Estimate is a three-page form that you receive after applying for a mortgage. The Loan Estimate tells you important details about the loan you have requested. The lender must provide you a Loan Estimate within three business days of receiving your application.

Are lot loans subject to HPML?

The definition of "higher-priced mortgage loan (HPML) starts section 1026.35(a) of Regulation Z: "(1) "Higher-priced mortgage loan" means a closed-end consumer credit transaction secured by the consumer's principal dwelling ...." A lot loan does not include a dwelling. Therefore it cannot be an HPML.

What section of TILA is HPML?

Main TILA HPML Appraisal rule provisions and official interpretations can be found in: § 1026.35, Requirements for higher-priced mortgage loans.

Can a borrower be charged for two appraisals?

The cost of only one (1) of the appraisals may be charged to the consumer/applicant. The other appraisal will be an expense of the lender.

Do HPML loans require escrow?

After you originate a higher-priced mortgage loan secured by a first lien on a principal dwelling, you must establish and maintain an escrow account for at least five years regardless of loan-to-value ratio.

What is considered a high cost mortgage loan?

Points and Fees Test

A mortgage is also considered to be a high-cost mortgage if its points and fees exceed: 5% of the total loan amount if the loan amount is equal to or more than $26,092 (2024), or. 8% of the total loan amount or $1,305, whichever is less, if the loan amount is less than $26,092. (12 C.F.R.