I know what you mean. When you think you have this stuff figured out, a small detail will trip you up every time.

I thought I had a good handle on the changes until little things that come up that make me read closer. Glad I'm not the only one!

Trivia: Do you remember the little girl's name, and who played her in the movie?

Regan; Linda Blair. And it's killing me to realize she's 55 now!

It would have been helpful if CFPB would have thrown in the word "MAY" somehow... as in "The HOEPA APR may differ from the TILA APR". Several resources were using language that seemed to indicate that it would ALWAYS vary, but in reality on fixed-rate loans it is the same. I appreciate that they were trying to give us a heads-up, but until you read more closely, it was a bit confusing.

Just to clarify, it does work to use the FFIEC Rate Spread Calculator to complete the APR test for HOEPA loans with apps on or after 1/10/2014, correct? It is confusing since the website says that it should not be used for HOEPA in bold letters on the page where you do the APOR spread calculation. Am I missing something?

You use the FFIEC calculator to get your spread over APOR for that portion of the HCML test.

Thanks dblack!