What loans are subject to HPML?

Asked by: Dr. Stephon Kulas MD  |  Last update: August 10, 2026
Score: 4.5/5 (71 votes)

Higher-priced mortgage loans (HPMLs) are closed-end consumer credit transactions secured by a borrower’s principal dwelling (including houses, condos, and manufactured homes) where the Annual Percentage Rate (APR) exceeds the Average Prime Offer Rate (APOR) by 1.5% for first-lien loans, 2.5% for jumbo loans, or 3.5% for subordinate liens. These loans are subject to specific appraisal, escrow, and repayment requirements.

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.

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 loans are excluded from HPML?

Which loans are exempt from HPML requirements?

  • Construction loans. HPML rules don't extend to construction loans to finance a newly built home. ...
  • Rural and underserved areas. ...
  • Planned unit development or condo association insurance.

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.
 

NMLS Exam - Section 35 of TILA: Higher Priced Mortgage Loans (HPML)

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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 loans does HOEPA not apply to?

HOEPA does not apply to reverse mortgages, new purchases, or construction or home equity lines of credit. If a loan is subject to HOEPA, the lender must make certain disclosures to the borrower at least three days before the loan is finalized.

What is the HPML threshold for 2025?

From January 1, 2025, through December 31, 2025, the threshold amount is $33,500. xiii. From January 1, 2026, through December 31, 2026, the threshold amount is $34,200.

Do HPML require two appraisals?

Higher Priced Mortgage Loans* (HPML) Property Flip Transactions. HPML* New Construction Properties with any title transfer within 180 days prior to the sales contract date, or any title transfer after the sales contract date, including land-only and zero value title transfers, require a Second Full Appraisal.

How to tell if a loan is HOEPA?

Mortgages secured by manufactured housing (whether titled as real property or personal property) and other types of personal property (e.g., an RV or a houseboat) are subject to HOEPA coverage if the dwelling is the consumer's principal dwelling.

What are the four types of mortgage loans?

The main types of mortgages are conventional loans, government-backed loans, jumbo loans, fixed-rate loans and adjustable-rate loans. There are other types of mortgages for specialized purposes, such as building or renovating a home or investing in property.

How much is a $400,000 mortgage at 7%?

A $400,000 mortgage at a 7% interest rate results in roughly $2,661/month for a 30-year loan and about $3,595/month for a 15-year loan, covering principal and interest, but doesn't include taxes, insurance, or PMI, which add hundreds more to the total monthly cost. The total interest paid over the life of a 30-year loan could exceed $550,000, making the overall cost close to $1 million. 

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 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 ...

Are HELOCs subject to HOEPA?

Under the 2013 HOEPA rule, most types of mortgage loans secured by a consumer's principal dwelling1, including purchase money mortgages, refinances, closed-end home-equity loans, and open-end credit plans (i.e., home equity lines of credit (HELOCs), are potentially subject to HOEPA coverage.

How to get 800 credit score in 45 days?

Getting an 800 credit score in just 45 days is challenging, as significant scores usually take time, but you can make rapid progress by focusing on paying down credit card balances to lower utilization (under 30%, ideally under 10%), paying all bills on time, disputing errors on your credit report, and possibly becoming an authorized user on a trusted account, while avoiding new credit applications. The most impactful actions for quick changes involve reducing high balances and fixing mistakes, as payment history and utilization are key factors. 

Do mortgage lenders look at 401k?

Mortgage lenders do look at 401(k) loans during the mortgage application process. The mortgage lender uses the 401(k) loan to determine the value of your 401(k) assets and your current debt obligations.