A closed-end consumer credit transaction secured by the consumer's principal dwelling is a high-cost mortgage, triggering 1026.32 and 1026.34, if its APR exceeds the average prime offer rate for a comparable transaction by more than 6.5 percentage points for a first lien (8.5 points for a smaller first-lien loan), or 8.5 points for a subordinate lien, or if its points and fees, or prepayment penalty structure, exceed the thresholds the rule sets (12 CFR 1026.32(a)).
The graph holds this control, the 0 it maps to, and the evidence behind each claim, over MCP and REST.