Does a loan need to be secured by the borrower's PRINCIPAL residence before a rate spread might be calculated or could it be a camp or vacation home and rate spread still apply?

Is this a HMDA question or an HPML question?

HMDA requires you to report the rate spread if the loan is subject to Reg. Z. A loan is only subject to the HPML test if it is secured by the primary residence of the borrower.

I guess it pertains to both hmda and hpml. I am scrubbing hmda and found some loans that needed to be reported that were not. I was not sure if I needed to check these for a rate spread to enter on the LAR.

I guess it boils down to this in a way then: a loan subject to Reg. Z secured by a borrower's vacation home that had a numeric rate spread would need to have it reported for HMDA, but having a numeric rate spread that exceeded the threshold for HPML on the same loan would be irrelevant, since the loan wasn't secured by the primary residence of the borrower.

Yikes. I am new to compliance and that just jumped right over my head. I know you report the rate spread if it is greater than 1.5 percentage points on a 1st lien and 3.5 percentage points on a 2nd lien. I also know you can use the FFIEC calculator to figure this. I cant tell from your post if I would put the rate spead on the LAR or if I would leave it off, if it would deal with principal residence or just dwelling secured.

If your loan is subject to Reg. Z (it's consumer purpose), then report the numeric spread on your LAR. All i was trying to say was that just because you have a numeric spread reported on your LAR doesn't mean that the loan is automatically subject to HPML (if it isn't secured by the borrower's primary residence).

Had to call my consultants but I think I have it now. Thanks so much for your help.