FORUM PROFILE

HOEPA vs. HPML vs. HPCT

Home Forums Compliance Masters Group (Members Only) HOEPA vs. HPML vs. HPCT

Viewing 2 posts - 1 through 2 (of 2 total)
  • Author
    Posts
  • #4068
    shea930
    Participant

    I’m trying to make sure I understand these 3 H’s correctly. I know they all have different thresholds and the property they cover varies. But I’m trying to figure out what the HPCT determines….

    For example:
    HOEPA – requires disclosure 3 days prior along with may other things
    HPML – requires escrows and verfity ablitity to repay
    HPCT – ????

    Does whether a loan is HPCT or not just affect whether the loan qualifies under the “safe harbor” or just the “rebuttable presumption”?

    #4070
    rcooper
    Keymaster

    Yes, if you have an HPCT QM it determines that you only get the rebuttable presumption of compliance rather than the safe harbor. Also if you have a non-QM balloon loan that is a HPCT you have to factor in the balloon payment into the payment calculation (see 1026.43(c)(5)(ii)).

Viewing 2 posts - 1 through 2 (of 2 total)
  • You must be logged in to reply to this topic.