Higher-Priced Mortgage Loan (HPML) Checker
A closed-end consumer loan secured by the borrower’s principal dwelling is a higher-priced mortgage loan when its APR exceeds the average prime offer rate (APOR) for its rate-set week by 1.5 points or more for a first lien, 2.5 for a jumbo first lien, or 3.5 for a subordinate lien, under 12 CFR 1026.35(a)(1). Enter a loan below to test it.
Is this loan a higher-priced mortgage loan?
Covers rates set from January 2, 2017 through November 1, 2026, against the CFPB’s weekly APOR tables. Nothing you enter leaves your browser.
The last date the rate was set before consummation.
The disclosed APR, not the note rate.
Term to maturity.
Principal at consummation.
Filled with the FHFA one-unit baseline for the lock year. Type over it for a high-cost county or a 2-4 unit property.
Key takeaways
- A loan is higher-priced when its APR is at least 1.5, 2.5 or 3.5 points over the APOR, depending on lien and loan size.
- The APOR comes from the week the rate was last set before consummation, matched on fixed or adjustable and on term.
- HMDA reports the same APR-minus-APOR figure as a number on reportable loans. The HPML test turns it into a yes or no.
What makes a loan higher-priced?
Regulation Z defines a higher-priced mortgage loan in 12 CFR 1026.35(a)(1) as a closed-end consumer credit transaction secured by the consumer’s principal dwelling whose APR “exceeds the average prime offer rate for a comparable transaction as of the date the interest rate is set” by a margin that depends on the lien and, for first liens, on the loan amount.
| Loan | APR over APOR that makes it an HPML | Rule |
|---|---|---|
| First lien, principal at or below the Freddie Mac maximum | 1.5 points or more | 1026.35(a)(1)(i) |
| First lien, principal above the Freddie Mac maximum (jumbo) | 2.5 points or more | 1026.35(a)(1)(ii) |
| Subordinate lien | 3.5 points or more | 1026.35(a)(1)(iii) |
An HPML carries extra rules. Section 1026.35(b) requires an escrow account for property taxes and insurance on a first-lien HPML, and 1026.35(c) adds appraisal requirements, each with its own exemptions. This page answers only the first question: does the loan meet the definition?
How is the APOR picked?
Three things choose the APOR a loan is measured against:
- The rate-set date. The official commentary to Regulation Z (comment 35(a)(1)-2) uses the last date the interest rate was set before consummation. A loan locked, then re-locked after rates moved, is tested against the week of the second lock.
- Fixed or adjustable. The CFPB publishes one APOR table for each. A fixed-rate loan uses the fixed table; an ARM uses the adjustable one.
- The term. Fixed loans are matched on term to maturity. ARMs are matched on the years until the first rate adjustment, so a 5/1 ARM amortized over 30 years uses the 5-year adjustable APOR.
Each weekly table applies from its Monday effective date until the next one takes over. Every published week since January 2, 2017 is on our APOR history explorer, which this checker reads from. Comment 35(a)(2)-3 says APOR means the same thing here as it does in Regulation C, so the HMDA guidance on picking the comparable transaction applies to both.
HPML vs HMDA rate spread: same inputs, different tests
Both start by subtracting the APOR from the APR. After that they part ways.
| HMDA rate spread | HPML test | |
|---|---|---|
| Rule | 12 CFR 1003.4(a)(12) (Regulation C) | 12 CFR 1026.35(a)(1) (Regulation Z) |
| Result | A number, positive or negative, reported to three decimal places | Yes or no |
| Rate-set date | Last date set before final action (comment 4(a)(12)-5) | Last date set before consummation (comment 35(a)(1)-2) |
| Lien status | Does not change the figure | Sets the threshold: 1.5 or 2.5 for a first lien, 3.5 for a subordinate one |
| Loan amount | Not used | Decides the first-lien threshold, against the Freddie Mac limit |
| Which loans | Originations and applications approved but not accepted that are subject to Regulation Z, except assumptions, purchased loans and reverse mortgages | Closed-end consumer credit secured by the consumer’s principal dwelling |
So a reported rate spread of 1.600 on a conforming first lien is also an HPML, while the same 1.600 on a jumbo first lien is not. The LAR carries the number but no HPML flag, so anyone reviewing HPMLs from HMDA data has to rerun the comparison with the lien and the loan amount. Comply HMDA/CRA calculates the rate spread for every loan on the LAR against these same weekly tables. Schedule your free demo today.
Worked example
Four made-up loans, all locked on August 20, 2026, so each uses the APOR table that took effect August 17, 2026. The APORs are the real published figures. The 2026 one-unit baseline limit of $832,750 decides the first-lien rows, assuming a county with no higher limit.
| Example loan | APR | APOR | Spread | Threshold | HPML? |
|---|---|---|---|---|---|
| 30-year fixed, first lien, $400,000 | 8.250% | 6.71% (30-year fixed) | 1.540 | 1.5 (first lien at or below the limit) | Yes |
| 30-year fixed, first lien, $900,000 | 8.250% | 6.71% (30-year fixed) | 1.540 | 2.5 (first lien above the limit) | No |
| 5/1 ARM, first lien, $400,000 | 7.900% | 6.30% (5-year adjustable) | 1.600 | 1.5 (first lien at or below the limit) | Yes |
| 15-year fixed, subordinate lien, $75,000 | 9.750% | 6.18% (15-year fixed) | 3.570 | 3.5 (subordinate lien) | Yes |
The first two loans carry the same APR and the same spread. Only the loan amount differs, and it moves the second one into the 2.5-point jumbo test, which it does not meet. On the LAR both would report a rate spread of 1.540.
Methodology and limits
The checker finds the most recent published APOR week on or before the date you enter, reads the column for the rate type and term, and subtracts it from the APR. It compares the result with the threshold for the lien and loan amount, using “or more” as the rule does, so a spread of exactly 1.5, 2.5 or 3.5 counts. The spread is shown to three decimal places.
- The APOR data is the CFPB’s fixed and adjustable tables, the files linked from the rate spread documentation, held exactly as published to two decimal places. 513 weeks, January 2, 2017 to the week of October 26, 2026, retrieved October 27, 2026.
- The Freddie Mac limit field is prefilled with the FHFA one-unit baseline for the calendar year of the lock date, 2017 to 2026, from FHFA’s annual announcements. It does not know the property’s county or unit count, so type the right limit over it where it differs.
- It leaves out the escrow and appraisal exemptions in 1026.35(b) and (c), and the separate high-cost (HOEPA) test in 1026.32. It is a reading of the definition, not legal advice. Rule text last checked November 10, 2026.
Outside the data range it says so instead of guessing. A date after the week of October 26, 2026 means this page needs its next APOR refresh.
HPML checker FAQ
What is the difference between APR and APOR?
The APR is the annual percentage rate of one specific loan, as disclosed under Regulation Z. The APOR is a market benchmark: an APR the CFPB derives each week from rates offered to prime borrowers, by loan type and term. The gap between the two is the rate spread, and it is the number both the HMDA rate spread field and the HPML test start from.
Is a loan exactly 1.5 points over the APOR a higher-priced mortgage loan?
Yes, if it is a first lien at or below the Freddie Mac limit. 12 CFR 1026.35(a)(1) says “by 1.5 or more percentage points,” so a spread of exactly 1.500 meets the test. The same holds at exactly 2.5 and 3.5 for the other two cases.
Which Freddie Mac loan limit decides the jumbo threshold?
The one in effect on the date the rate was set, for the property’s county and number of units. The official commentary to Regulation Z says the FHFA sets that maximum. For most one-unit properties it is the national baseline, $832,750 in 2026 according to the FHFA’s announcement. High-cost counties, two- to four-unit properties and a few states and territories have higher limits, listed on the FHFA conforming loan limit page.
Does the HMDA LAR have an HPML field?
No. The LAR carries the rate spread itself (12 CFR 1003.4(a)(12)) and a separate HOEPA status field for high-cost mortgages under 12 CFR 1026.32, which is a different test from HPML. A reviewer who wants to know which reported loans were HPMLs has to rerun the 1026.35 comparison from the rate spread, the lien status and the loan amount.
Sources
- 12 CFR 1026.35, Requirements for higher-priced mortgage loans, eCFR, paragraphs (a)(1) and (a)(2). Retrieved November 10, 2026.
- Supplement I to Part 1026, Official Interpretations, comments 35(a)(1)-1 to -3 and 35(a)(2)-3, eCFR. Retrieved November 10, 2026.
- 12 CFR 1003.4(a)(12), rate spread, and Supplement I to Part 1003, comments 4(a)(12)-4 and -5, eCFR. Retrieved November 10, 2026.
- CFPB APOR tables on the FFIEC HMDA platform: YieldTableFixed.txt and YieldTableAdjustable.txt. Retrieved October 27, 2026.
- Conforming Loan Limit Values, Federal Housing Finance Agency, and its yearly news releases (2026). Retrieved November 10, 2026.
Quoting a figure? Cite this page
To cite it: RATA Associates, “Higher-Priced Mortgage Loan (HPML) Checker,” rule text checked November 10, 2026, APOR data pulled October 27, 2026, https://rataassociates.com/higher-priced-mortgage-loan-checker/.
You may republish the threshold table, the worked example and the explanations on this page with attribution to RATA Associates and a link to this page.
