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#1533029 - 04/07/11 04:52 PM APR out of tolerance (unintentionally)

I would appreciate any and all input on a possible cure for this violation.

I realize I can not "un-do" this loan. I just want to address the issue before the examiners have the opportunity.

We are a small bank who only made two residential real estate loans last year. (We have since stopped completely) We "thought" we priced them to a point where they would not be considered to be a higher priced mortgage loan. The APR is out of tolerance, due to a prepaid finance charge. If I refund the prepaid finance charge (Flood Determination Fee), the APR is still out of tolerance, by .02%.

How do I mend this mistake?

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#1533260 - 04/08/11 10:55 AM Re: APR out of tolerance (unintentionally) [Re: Anonymous]
rlcarey Offline
10K Club

Registered: 07/16/01
Posts: 54254
Loc: Galveston, TX
When you say out of tolerence, you mean the APR is out of tolerence or that it just was a HMPL?

An APR tolerence violation will require restitution to cure.

An HPML violation - there is no cure.
The opinions expressed are my own, take them or leave them.

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