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#196006 - 06/02/04 05:11 PM June HOEPA Schedule
Suzie Offline
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Suzie
Joined: Apr 2002
Posts: 662
Far North
I'm confused! This morning the BOL Compliance briefing indicates to use the rate as of 17th of May, as the 15th fell on a Saturday. The TIL Exam procedures indicate if the 15th is not a business day use the business day immediatley preceding the 15th -- and last month that would have been the 14th.

I have sent out my schedule with the rate for the 14th -- Am I wrong?
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Lending Compliance
#196007 - 06/02/04 06:11 PM Re: June HOEPA Schedule
Andy_Z Offline
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Andy_Z
Joined: Oct 2000
Posts: 27,748
On the Net
An errata was sent on that clarifying it. You were referred to the index posted for the 17th. In that is the 14th, which wasn't specified as the column of data to use. Thanks to those pointing out our confused state.

"The Federal Reserve has posted the new reference rates which lenders must use to determine if loans for which applications are received in June 2004 will be subject to HOEPA under the APR trigger test. Use the FRB H.15 to find applicable release which lists the Treasury Security with the same maturity term as your loan. To make the calculation, you use the yield in effect on the 15th of the month that precedes the month you received the application. For June, you will use the rates posted on May 14th* since May 15th fell on the weekend."
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