Regulatory guidance indicates...If an interest rate is set pursuant to a "lock-in" agreement between the lender and the borrower, then the date on which the agreement fixes the interest rate is the date the rate was set. If a rate is re-set after a lock-in agreement is executed (for example, because the borrower exercises a float-down option or the agreement expires), then the relevant date is the date the rate is re-set for the final time before closing. If no lock-in agreement is executed, then the relevant date is the date on which the institution sets the rate for the final time before closing. Can someone define rate "re-set"? Would that include extensions?

We use the date the rate lock is executed or the date the rate lock was last modified, such as an extension.

Just adding onto this..

We have a Home Equity Product that is one rate, it's technically locked at the point of approval. However, the lenders are using the date the loan docs are drawn for their rate lock. Would this be accurate at the rate is already set and cannot change per our bank's lending policy? Any help is appreciated!

it's technically locked at the point of approval

If the rate will not change under any circumstance once the loan is approved then the date of approval is the date you last set the rate and the date you should be using for comparison to the APOR.

Thank you Dan!