Regulation Z requires High Price Mortgage Loans (HPML) to be identified.

The HMDA Rate Spread provides adequate proof of the borrower's ability to repay must be provided if the rate spread is greater than:

• 1.5% on 1st liens
• 3.5% on Jr. liens

HMDA Rate Spread is required when the loan requested is:

• Originated
• Secured by a dwelling or by a multi-family structure
• Purpose is purchase, improvement, renewal or refinance of a dwelling or multi-family structure