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Regulation Z: HOEPA and Higher-Priced Mortgage Loans (HPML) Requirements and Regulations


Understand the various requirements for loans that meet the HPML definition.

The Regulation Z Higher-Priced Mortgage Loan (HPML) rule imposes numerous detailed, specific, and often operationally-burdensome requirements on defined higher-priced mortgage loans. These requirements require significant operational and compliance oversight and can invoke secondary market investors and other requirements. While the HPML rule has been in place for several years, the myriad details and impacts of this rule warrant complete refresher updates for all persons who deal with the issue, as well as thorough training for new employees. This course will help those working in underwriting and loan origination activities, and all those responsible for adherence to and oversight of HPML requirements, to understand the definition of HPML and what loans meet the definition; as well as the various requirements for loans that meet the HPML definition, such as when escrow accounts must be utilized, and the appraisal requirements specific to HPMLs. The course will also help you understand what regulators and agencies can enforce the HPML rule and possible penalties for violations. Finally, you will learn about some of the interplays between the HPML rule and investor requirements and how the HPML rule overlays and interacts with the qualified mortgage rule and the high-cost mortgage rule.



Michael C. Flynn

Michael C. Flynn


  • Of Counsel at Buchalter and is a member of the firm’s Commercial Finance Practice Group and Mortgage Banking Group, and co-chair of its Financial Services Regulatory Group and Title Insurance & Escrow Industry Group
  • He applies his unique background as the former Acting General Counsel of HUD and the former General Counsel of PNC Mortgage and Flagstar Bank, to counsel clients on a variety of regulatory, mortgage, consumer financial services, FinTech, and real estate matters
  • Frequent speaker at different events, including California and Federal Legislative Update, California Mortgage Bankers Association Legal Affairs and Regulatory Compliance Conference, December 8, 2021; UDAAP, California Mortgage Association 2021 Summer Seminar, July 30, 2021; and UDAAP Exposure: How Can Banks Manage the Increased Risk?, Western Bankers Association 2021 Directors Virtual Workshop, June 23, 2021
  • Author of many publications, including Conference on Consumer Finance Law Quarterly Report - A Look at Federal, New York, and California COVID-19-Related Mortgage Forbearance, Foreclosure, and Eviction Moratoria: Can Expanded Protections Become Permanent?, 2022; American College of Mortgage Attorneys Spring Abstract - New COVID Residential Mortgage Borrower and Tenant Protections in California: Significant Temporary Mandates - Can They Become Permanent Requirements?, 2021; and National Mortgage News - Opinion: Preparing for the Return of Rescission Claims, 2020
  • Memberships include fellow of the American College of Mortgage Attorneys and chair of its Residential & Regulatory Committee; chair of CA Lawyers Ass’n Financial Institutions Committee; chair of the California Mortgage Bankers Association Legal Affairs Committee; Board of Regents of the Conference on Consumer Finance Law; fellow of the American College of Consumer Financial Services Lawyers; fellow of the American College of Real Estate Lawyers; member of American Bar Association Business Law and Litigation Sections and the Consumer Financial Services and Banking Law Committees; former chair of ABA Title Insurance Litigation Committee; former chair of ABA Banking Subcommittee on Retail and Consumer Finance Law; ABA Observer to the Uniform Law Commission’s drafting of proposed Uniform Home Foreclosure Procedures Act; former chair of ABA Business Law Section Task Force on Litigation Reform; former member of ABA Business Law Section Working Group on Electronic Evidence; former co-chair of ABA Business Law Section Subcommittee on In-House Litigation Management; former member of the American Land Title Association Claims Committee
  • J.D. degree, Duke University School of Law, William Neal Reynolds Scholar; B.A. degree, Indiana University, Arthur R. Metz Distinguished Scholar, Phi Beta Kappa
  • Can be contacted at [email protected], 213-891-5262 or 415-377-6048

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