who must test loan for hpml expection
HPML - Calculating Repayment Ability. We are working on the Reg. Z changes that came out Oct. 1, in relation to a higher price mortgage loan (HPML). We offer one, three, or five year ARM loans which meet the test for a HPML. All three of our ARM types originate at an index + margin (fully indexed rate) and are subject to an adjustment either at one, three or five years based on whatever the index is at that time plus the same margin the loan originated with.