A team member asks about TILA HPML Appraisal Rules in a compliance desk review while trying to decide how the file should be documented. Which response should a processor use?
Correct Answer
B) Use the subordinate-lien threshold when the loan is junior-lien
HPML coverage depends on APR-over-APOR thresholds and carries escrow or appraisal duties. The best answer is "Use the subordinate-lien threshold when the loan is junior-lien".
Why This Is the Correct Answer
HPML coverage depends on APR-over-APOR thresholds and carries escrow or appraisal duties. The best answer is "Use the subordinate-lien threshold when the loan is junior-lien".
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