There are many thread discussions on rate lock extensions as they relate to RESPA and Reg Z. Most postings seem to agree the date of a rate lock extension, whether before or after the original lock expires, triggers a revised GFE and serves as rate re-set date for Reg Z tests.
We do not sell directly to FNMA but I ran across a HOEPA worksheet, dated August 2014, that FNMA requires on files selected for QC review and it includes this definition:
"Rate Lock Date: The last date the interest rate is set before closing of the loan (except if a rate lock is extended without a change in the rate prior to expiration of the rate lock period, the Rate Lock Date remains the date on which the interest rate was last set)"
I take this to mean FNMA doesn't count extension of an unexpired lock as a re-set date for HOEPA, and presumably rate spread.
Isn't this in conflict with current thinking--or is it?
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