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#1287939 - 11/17/09 06:09 PM Rate Spread
HMDA Specialist Offline
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Do we have to report the Rate Spread for Investment Properties and Second Homes?

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#1288027 - 11/17/09 07:07 PM Re: Rate Spread HMDA Specialist
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Somebody can help me?

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#1288038 - 11/17/09 07:12 PM Re: Rate Spread HMDA Specialist
dg Offline
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Pacific NW
If it for business prupose than no. Business purpose is not subject to Reg Z.

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#1288052 - 11/17/09 07:20 PM Re: Rate Spread dg
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The second home is not for business purposes. For example a Beach Apartment???

Do we report RS?

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#1288067 - 11/17/09 07:25 PM Re: Rate Spread HMDA Specialist
dg Offline
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The second home should be reported if a purchase, home improvement or refi. You would report rate spread after calculation if there is one.

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#1288133 - 11/17/09 08:05 PM Re: Rate Spread dg
Dan Persfull Offline
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Bloomington, IN
Quote:
Do we report RS?


http://www.ffiec.gov/hmda/guide.htm

Search the GIR using rate spread as the search term and you will find, on page A-9, that any loan subject to the disclosure requirements of 226.6 and 226.18 requires the reporting of the rate spread.
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#1288203 - 11/17/09 08:38 PM Re: Rate Spread Dan Persfull
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If the Beach Apartment is non-owner occupied rental housing, then it is not subject to Reg Z and if the loan is not subject to Reg Z then you enter NA for Rate Spread.

If the Beach Apartment is a 2nd home and not for Business Purposes and not a rental home then it is subject to Reg Z and the rate spread would need to be completed.
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#1291928 - 11/23/09 10:25 PM Re: Rate Spread ClassAct
mforr Offline
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Posts: 28
Missouri
I agree that the GIR says the rate spread should be reported for a second home, but does the APOR take into account primary and second homes? Since second homes aren't subject to the HPML test, are we comparing like transactions to determine the rate spread for HMDA?

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#1292270 - 11/24/09 04:17 PM Re: Rate Spread mforr
Dan Persfull Offline
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Bloomington, IN
Quote:
does the APOR take into account primary and second homes

Not that I'm aware of.

For HMDA reporting purposes it doesn't matter if HPML applies or not. If the loan is for a consumer purpose and dwelling secured then you must report the rate spread.

If I own a 15 unit apartment building and I borrower against that building to pay for my grandson's college tuition that is a consumer purpose loan subject to Reg Z 226.18 disclosures and it is dwelling (multi-family) secured, therefore the rate spread for HMDA reporting is applicable.
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#1742363 - 09/19/12 08:43 PM Re: Rate Spread HMDA Specialist
Many Hats Offline
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Orlando, FL
Ok...and on another topic.....even though it is a purchase of a second home, MDIA (waiting periods) still apply....correct?

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#1742459 - 09/20/12 12:39 PM Re: Rate Spread HMDA Specialist
Dan Persfull Offline
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Dan Persfull
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Bloomington, IN
Yes. 1026.19(a) no longer references the consumer's primary residence.
_________________________
The opinions expressed are mine and they are not to be taken as legal advice.

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