This might be a stupid question but shouldn't we run the APR test for QM and HOEPA against the APR on the final TIL and not just the APR on the initial TIL?

There isnt' a huge difference usually but for accuracy sake I think the test needs to be run against the final TIL APR.

Yes?

You check as of the date the interest rate is set.

But you are correct that the final APR is what matters. The APOR table you use is what ties to the date the interest rate is last set.

Thank you.
So if the rate was set on a Thursday but we didn't run the APR against the APOR until the following Tuesday we might have an issue since the APOR is updated each Monday.
Yes? I should retest any loan where the test was not run in the same week as the rate lock?