I just want to make sure I am understanding the changes to what is an HPML with the June 1 changes.
Before the June 1 changes, the APR 2.5 above APOR threshold for 1st lien jumbos had previously been just for the escrow requirement. So if we did a jumbo loan and the APR was 1.90 above the APOR then it would be an HPML, but we would not have to require the escrow but follow all the other rules for HPMLs.
However, with the changes effective June 1, it looks like the definition has been changed to include the 2.5 or above for Jumbos. So if we did a jumbo loan and the APR was 1.90 above the APOR then it would not be a HPML at all. Is this correct? With all the changes I really am questioning some of the more basic aspects of the regs and changes 😕 Thanks in advance.