Regarding the revisions to Reg Z effective October 1, 2009 for Higher Priced Loans.

Am I reading that the regulation correctly the higher priced loans include government loans (FHA, VA, Rural Development) and Rehab loans (loan funds to cover the purchase and rehabilitation of a dwelling)?

No matter what "Type" of loan
If it is a Closed End loan ; 1st or jr. lien ; on the primary residence of the borrower - - you then would have to run the Rate Spread Calculator to determine if the loan is HPML.
Just my opinion - Now that the secondary market has essentially stopped buying anything but "Prime" loans I expect the Standard Conventional; FHA ; VA (Secondary Market) loans will be close to the prime offer rate and therefore I don't expect any of those that we make to fall into the HPML "bucket" ?

Can someone remind where to find the rate spread calculator information?

This should be what you are looking for:

http://www.ffiec.gov/ratespread/default.aspx

We were looking at the actual Freddie Mac Survey because the FFIECs calculator was still linked to the Treasury rate when it first appeared. http://www.freddiemac.com/dlink/html/PMMS/display/PMMSOutputYr.jsp I have been wondering if we should be using just the Average Rate or should we include the column for points and fees as well. Has anyone seen that clarified?

Thanks. So do we know if the FFIEC calculator is still linked to the Treasury rate or has that been updated now?

The FFIEC now has links to both the old rate spread (using the Treasury tables) and to the new APOR tables.

http://www.ffiec.gov/ratespread/default.aspx

Thanks everyone!!!

Help me with the APOR calculator for adjustable. Suppose I'm doing a one year loan consumer purpose secured by consumer's principal dwelling. Loan is P+2 floating from day one with a 5.5% floor. What input do I put in the calculator? The shortest fixed term in the calculator for an ajustable rate loan is one year. That's not my first fixed period for this loan, it's one day.