I’m confused about HPML and if section 35 still exists.
Am I thinking clearly that section 32 and 35 are now called Higher Priced Morgage Loans and both now are tied to APOR and now sections 1026.32 and 1026.34. Is the only thing under section 35 the escrow portion now?
Can you also expalin the HPCT Higher Priced Coverd transaction?? Is a HPML and HPCT the sams?
HPML and 1026.35 does still exist. There are different thresholds that qualify a loan as either a higher priced mortgage loan (HPML, 1026.35), a high cost mortgage loan (HCML/HOEPA, 1026.32) or a higher priced covered transaction (HPCT, 1026.43). These prior posts address the differences: