What loans are excluded from HPML?

Asked by: Isadore Lakin  |  Last update: October 2, 2026
Score: 4.1/5 (52 votes)

Loans excluded from Higher-Priced Mortgage Loan (HPML) rules (like appraisal & escrow) often include initial construction loans, short-term bridge loans (≤12 months), reverse mortgages, loans for mobile homes/boats/trailers, loans below a certain dollar threshold (indexed annually), certain streamlined refinances, and loans for non-principal residences or business purposes, plus specific exemptions for small lenders and unique property types like cooperative shares.

What types of loans are excluded from HPML?

New § 1026.35(b)(2)(vi) exempts from the Regulation Z HPML escrow requirement any loan made by an insured depository institution or insured credit union and secured by a first lien on the principal dwelling of a consumer if: (1) The institution has assets of $10 billion or less; (2) the institution and its affiliates ...

What is considered an HPML loan?

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.

Are reverse mortgages excluded from HPML?

If your organization is eligible for the small creditors exemption or the insured institution exemption, but you originate an HPML under a forward commitment for sale (i.e.,your organization will not hold the loan in portfolio), you must establish an escrow account unless the loan is otherwise exempt (for example, it ...

What types of loans are exempt from HOEPA?

As discussed above, HOEPA applies to most types of consumer credit transactions secured by a consumer's principal dwelling. As a result, mortgages secured by vacation or second homes are not covered.

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How to determine if a loan is an HPML?

An HPML does not include a second home or Investment Property. 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. APR and APOR are both defined in Regulation Z.

What are 7 types of loans?

Seven common types of loans include Personal Loans, Auto Loans, Student Loans, Mortgage Loans, Home Equity Loans, Payday Loans, and Debt Consolidation Loans, each serving different financial needs, from major purchases like cars and homes to consolidating debt or managing unexpected expenses.
 

What mortgages do not require PMI?

Government-backed loans like VA, USDA, and FHA offer options to skip PMI, especially helpful for first-time buyers with smaller down payments. Non-QM loans like jumbo, bank statement, DSCR, and asset-based mortgages do not have PMI requirements.

How to determine HPML?

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.

What loans are exempt from regulation Z?

Coverage Considerations under Regulation Z

(Exempt credit includes loans with a business or agricultural purpose, and certain student loans. Credit extended to acquire or improve rental property that is not owner-occupied is considered business purpose credit.)

How to avoid HPML?

How to avoid HPML loans

  1. Don't take out an FHA loan.
  2. Boost your credit score.
  3. Make a bigger down payment.
  4. Ask the seller to pay closing costs.
  5. Reconsider buying a manufactured home.

What are the three main types of loans?

What are the standard types of home loans?

  • Variable rate loans. With a variable rate loan, your interest rate can move up or down. ...
  • Fixed rate loans. The interest rate on a tailored fixed rate loan is fixed for a set period—usually one to five years. ...
  • Split loans. ...
  • Principal and interest repayments. ...
  • Interest-only repayments.

What is not a characteristic of an HPML?

The characteristic that is not associated with HPML is that it has an APR exceeding Treasury securities by 6.5 percentage points. All other options reflect true characteristics of HPML.

What is the 3 7 3 rule in mortgage?

The 3-7-3 Rule in mortgages isn't a loan type but a federal timeline from the TILA-RESPA Integrated Disclosure (TRID) rule, ensuring borrower protection by mandating disclosures within 3 business days of application, a 7-business-day wait between the initial Loan Estimate and closing, and another 3-day wait if significant changes (like APR) occur, giving borrowers time to review costs before committing to a loan.

What loans are exempt from HOEPA?

(construction loans and loans originated and financed by Housing Finance Agencies are exempt.) The second method that the Dodd-Frank Act used to expand HOEPA coverage was an expansion of the APR and Points and Fees triggers.

Who is exempt from PMI?

Some lenders offer exclusive mortgage programs that require low down payments without PMI. These programs often target first-time buyers, lower-income households, or specific professions (like teachers and doctors), and they typically require higher credit scores or charge higher interest rates.

Does PMI apply to all loans?

PMI typically is required for conventional loans when the homebuyer makes a down payment of less than 20 percent. PMI protects the lender (not the borrower) from losing money when a homeowner defaults on a mortgage loan.

What are the four C's of loans?

The 4 Cs of lending are Capacity, Capital, Credit, and Collateral, a framework lenders use to assess a borrower's creditworthiness by evaluating their ability to repay a loan, their existing financial reserves, their credit history, and the assets securing the loan, respectively. These factors help lenders gauge risk, making it easier for borrowers with strong profiles to get approved for mortgages and other loans. 

What are the 5 types of loans?

What Are the 5 Most Common Loan Types? As a loan officer, five of the most common loan types you'll handle are as follows: mortgages, seed or working capital for small businesses, automotive loans, school loans, and personal loans.

What are stage 3 loans?

Stage 3 loans which are in cure period. Quantitative indicator: i. Past due more than 90 days and up to 120 days.