Has anyone happened to get guidance from CFPB as to the "Average Rate" for loans insured under Title I of the National Housing Act - the unpublished rate to be used for the APR test on titled mobile homes?

From what I have been able to gather (including a BOL webinar from Mary Beth and Jack from August) basically CFPB has said that they don't anticipate many of these so call when you get one for specific guidance. I've called twice to inquire about their established work-around. It's been three weeks now and I still don't have a response. If this is the turn-around time in a live environment, no one will be able to make these loans!

Just curious if anyone had talked to CFPB on mobile homes and could share their insight - or any luck in general getting CFPB to return calls this time of year...

I just got off the phone with CFPB - unofficial guidance only but I wanted to relay and clarify a bit from the original post:

First, the 'average rate' is to be determined by each bank by looking at their current market rates for the area(s) they operate.

Second, from the webinar handouts (I wasn't able to participate live, I only reviewed the materials courtesy of a co-worker last month) I was under the impression that we needed to compare personal property loans (commonly mobile homes) with this 'average rate' instead of the standard APOR threshold comparison under the APR test. That is INCORRECT!! The average rate is needed to determine if you have bona fide discount points for your points and fees test.

My apologies for any confusion this may have caused.