Skip to content
BOL Conferences
Thread Options
#1900963 - 02/28/14 12:03 AM APR TRIGGER
Complianceking Offline
Gold Star
Joined: Dec 2005
Posts: 437
West Coast
Could someone please explain to me in lay terms the following: APR at consummation will exceed by more than 8% the yield on Treasury securities having comparable periods of maturity on the 15th day of the month immediately preceding the month in which the application is received by the creditor. I would like to explain it in plain English to our production staff in a training session concerning High Cost Loans, so that they would understand it without getting confused. Any guidance would be appreciated.

Return to Top
Lending Compliance
#1900975 - 02/28/14 01:49 AM Re: APR TRIGGER Complianceking
Norman Paperman Offline
Diamond Poster
Norman Paperman
Joined: Aug 2012
Posts: 1,700
48.934476, -114.343735
Your APR exceeds APOR by more than 8%.

Don't do the loan. laugh
_________________________
Maybe you just wanna fly the plane yourself. Well good luck pressing take off, then auto pilot, then land.


CRCM

Return to Top
#1900992 - 02/28/14 01:21 PM Re: APR TRIGGER Complianceking
RR Joker Offline
10K Club
RR Joker
Joined: Nov 2002
Posts: 20,656
The Swamp
What ^^^ said. Now, if that's not what you are looking for, can you be a bit more specific about what part you want to re-word?
_________________________
My opinion only. Not legal advice.

Say you'll haunt me - Stone Sour

Return to Top
#1901377 - 02/28/14 08:13 PM Re: APR TRIGGER Complianceking
Complianceking Offline
Gold Star
Joined: Dec 2005
Posts: 437
West Coast
Thanks for your guidance.

Return to Top
#1901398 - 02/28/14 08:44 PM Re: APR TRIGGER Complianceking
dblack Offline
Gold Star
Joined: Feb 2008
Posts: 263
AL
Originally Posted By: Complianceking
Could someone please explain to me in lay terms the following: APR at consummation will exceed by more than 8% the yield on Treasury securities having comparable periods of maturity on the 15th day of the month immediately preceding the month in which the application is received by the creditor. I would like to explain it in plain English to our production staff in a training session concerning High Cost Loans, so that they would understand it without getting confused. Any guidance would be appreciated.


That's the wording for the old section 32. I don't know that you will gain much by training on this since it was replaced 1/10/14.
_________________________


CRCM



Return to Top
#1901487 - 02/28/14 10:37 PM Re: APR TRIGGER Complianceking
Complianceking Offline
Gold Star
Joined: Dec 2005
Posts: 437
West Coast
Would you happened to have the link to the new wording that was replaced on 1/10/2014?

Return to Top
#1901533 - 03/03/14 02:09 PM Re: APR TRIGGER Complianceking
dblack Offline
Gold Star
Joined: Feb 2008
Posts: 263
AL
http://www.bankersonline.com/regs/12-1026/12-1026-032.html

The requirements of this section apply to a high-cost mortgage, which is any consumer credit transaction that is secured by the consumer's principal dwelling, other than as provided in paragraph (a)(2) of this section, and in which:

(i) The annual percentage rate applicable to the transaction, as determined in accordance with paragraph (a)(3) of this section, will exceed the average prime offer rate, as defined in ยง 1026.35(a)(2), for a comparable transaction by more than:

(A) 6.5 percentage points for a first-lien transaction, other than as described in paragraph (a)(1)(i)(B) of this section;

(B) 8.5 percentage points for a first-lien transaction if the dwelling is personal property and the loan amount is less than $50,000; or

(C) 8.5 percentage points for a subordinate-lien transaction
_________________________


CRCM



Return to Top

Moderator:  Andy_Z