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#1653522 - 01/20/12 03:39 PM Rate Spread - applicable when collateral is not RE
Many Hats Offline
Platinum Poster
Joined: May 2008
Posts: 915
Orlando, FL
When the collateral offered on a loan is not real estate, if the purpose was home improvement (and let's say a car was used as the collateral), would you need to calculate a rate spread?

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#1653528 - 01/20/12 03:33 PM Re: Rate Spread - applicable when collateral is not RE Many Hats
Dan Persfull Offline
10K Club
Dan Persfull
Joined: Aug 2002
Posts: 47,532
Bloomington, IN
No.
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The opinions expressed are mine and they are not to be taken as legal advice.

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#1653533 - 01/20/12 03:49 PM Re: Rate Spread - applicable when collateral is not RE Many Hats
Many Hats Offline
Platinum Poster
Joined: May 2008
Posts: 915
Orlando, FL
That's what I thought....ok.....and a follow up question....does the same apply to HEOPA? If it's not RE secured, there's no need to test for HOEPA?

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#1653548 - 01/20/12 04:05 PM Re: Rate Spread - applicable when collateral is not RE Many Hats
Many Hats Offline
Platinum Poster
Joined: May 2008
Posts: 915
Orlando, FL
NEVER MIND :0)

The answer is no...having a blonde moment (no offense).

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