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#1744777 - 09/27/12 04:02 PM HMDA Rate Spread
tumbleweed Offline
Member
Joined: Apr 2004
Posts: 86
Michigan
Are we out of compliance if we over report in the rate spread field. Example: If we have an investor property and we report the rate spread (3.23) over tolerance rather then "NA"?

If we consider this investor property business purpose Reg Z would not fall into place and under HMDA if the loan is not subject to Reg Z enter NA in the rate spread. But we have been reporting the rate spread field on investor property.
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All statements are my own and not necessarily those of my employer.

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#1744847 - 09/27/12 05:25 PM Re: HMDA Rate Spread tumbleweed
Dan Persfull Offline
10K Club
Dan Persfull
Joined: Aug 2002
Posts: 47,533
Bloomington, IN
Reporting a rate spread on the LAR when it should have been NA will result in in cited errors on your LAR at exam time.
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The opinions expressed are mine and they are not to be taken as legal advice.

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#1744968 - 09/27/12 07:51 PM Re: HMDA Rate Spread tumbleweed
tumbleweed Offline
Member
Joined: Apr 2004
Posts: 86
Michigan
Are investor properties considered business purpose therefore the rate spread field should be populated with NA?
_________________________
All statements are my own and not necessarily those of my employer.

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