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#1248668 - 09/11/09 02:40 PM HMDA LAR and HPML
dottiec Offline
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Joined: Jul 2007
Posts: 305
I finally got around to reviewing the requirements to report HPML rate spreads on our HMDA LAR. The Pricing-Related Data instructions require us to report the date the interest rate was set. I cannot find a field for that on the LAR data entry screen. Is there new software out from the FFIEC?
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#1248702 - 09/11/09 03:04 PM Re: HMDA LAR and HPML dottiec
CompDat Offline
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Joined: Dec 2005
Posts: 553
USA
Im not sure what you are referring too, but the old rate spread rules required a "date of rate lock" to determine the rate spread. I don't think they are referring to anything different.

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#1248716 - 09/11/09 03:12 PM Re: HMDA LAR and HPML CompDat
dottiec Offline
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Joined: Jul 2007
Posts: 305
So there is no field where the date must be enetered on the LAR?
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#1248758 - 09/11/09 03:38 PM Re: HMDA LAR and HPML dottiec
ktac MITCH Offline
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ktac MITCH
Joined: May 2005
Posts: 1,813
Giant side of TX
There is no field on the LAR for rate lock date.

You have to know the rate lock date in order to properly calculate the Rate Spread & determine if you have a reportable rate spread. = No change from HMDA procedures in the past.
The change is in what is a reportable rate spread.
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#1248985 - 09/11/09 06:22 PM Re: HMDA LAR and HPML ktac MITCH
dottiec Offline
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Joined: Jul 2007
Posts: 305
Thank you for your help. That is one thing off my thousand item to-do list!
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