HPML Rate Spread Calculator
Section 35 Compliance & Regulation Z Verification
First Lien (Non-Jumbo)
Jumbo First Lien
Subordinate (Second) Lien
Select the appropriate threshold based on the loan position.
Calculated Rate Spread:
0.00%
Applicable Threshold:
1.50%
Understanding the HPML Rate Spread
A Higher-Priced Mortgage Loan (HPML) is defined under Regulation Z (Section 1026.35) as a consumer credit transaction secured by the consumer's principal dwelling with an Annual Percentage Rate (APR) that exceeds the Average Prime Offer Rate (APOR) by a specific threshold.
How is the Spread Calculated?
The calculation is simple but critical for regulatory compliance:
Rate Spread = Loan APR – APOR Rate
Regulatory Thresholds:
- 1.5 percentage points for first-lien loans.
- 2.5 percentage points for first-lien "Jumbo" loans (where the principal amount exceeds Freddie Mac/Fannie Mae limits).
- 3.5 percentage points for subordinate (second) lien loans.
Why Does HPML Classification Matter?
If a loan is classified as an HPML, lenders must adhere to stricter requirements, including:
- Escrow Requirements: Mandatory escrow accounts for property taxes and insurance for at least five years.
- Appraisal Requirements: In some cases, a written appraisal and a second appraisal for "flipped" properties may be required.
- Ability to Repay: Lenders must verify the consumer's ability to repay the loan.
Note: APOR rates are updated weekly by the FFIEC. Ensure you use the APOR rate in effect as of the date the interest rate for the loan was set.