Hi All,

HMDA reporting question- We took an online app and one of the questions that the customer answered is "Do you want to lock-in the rate" at 4%. Customer selected "YES"

One week later we send out a "rate lock agreenment" asking customer if they want to lock in or float. Customer wants to lock-in.

Is the lock in date the app date, becouse we ask that on the app process? OR is it when they sign the agreement we send to them?

Thanks all!

You need to consult with the latest version of HMDA's Guide to Getting it Right. This is the HMDA bible. You can google it and download it too

It states in mine that the lock date is "the date that the loan's interest rate was set by the financial institution for the final time before closing."

The date you use for the rate spread calculation is the date you last set the rate. So did you last set the rate on the date the online app was submitted or when the executed lock agreement was received?

Yes. I have the HMDA guide

We set the date as the executed date when the customer signed the "rate lock agreement"

I'm sorry, some are not aware that it's out there. I hope I didn't offend.

I understand, no problem

Follow-up to a rate lock question.

If we chose to report HELOC's(home improvments) do we need to report the rate lock date and the APR?

I have never seen a rate lock on a HELOC.

The issue you face is if your index moves from the date you lock the rate and your initial rate is not within the tolerance specified in the Plan disclosure then you run the risk of having a discounted or premium rate at consummation which would require a new Plan disclosure. I would advise using the consummation date as the date you last set the rate for a HELOC.

Unless this is a fixed rate HELOC.......

Yes. Fixed rate HELOC. Strange programs offer at this institution. Is this anywhere in the FFIEC guide? Management will challenge that it's not needed to be reported…...

Page A-8:

To determine whether
the rate spread meets this
threshold, use the average
prime offer rate in effect for the
type of transaction as of the
date the interest rate was set,
and use the APR for the loan,
as calculated and disclosed to
the consumer under § 226.6
or 226.18, as applicable, of
Regulation Z (

Looking for some advise. In regards to HE loans, is the rate lock needed on the LAR?

Here's a quote from our mtg people...

"We not have a rate lock policy for HE loans and in fact the rates for those loans have not really fluctuated in years. Policy is that the customer gets the lower of the prevailing rate at time of application or time of closing. You will never find a lock date for any HE loans/lines"

Is this true?

customer gets the lower of the prevailing rate at time of application or time of closing.

That tells me the rate is last set at the time of closing and that should be your date.

Thank you!

Last thing. Please confim the rate lock date is needed on the LAR? Cannot be left blank... As per

Page A-8:

To determine whether
the rate spread meets this
threshold, use the average
prime offer rate in effect for the
type of transaction as of the
date the interest rate was set,
and use the APR for the loan,
as calculated and disclosed to
the consumer under § 226.6
or 226.18, as applicable, of
Regulation Z (

You don't put a rate lock date on the LAR, you put the rate spread, as applicable.