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#1900963 - 02/28/14 12:03 AM APR TRIGGER
Complianceking Offline
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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.

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#1900975 - 02/28/14 01:49 AM Re: APR TRIGGER Complianceking
Norman Paperman Offline
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Your APR exceeds APOR by more than 8%.

Don't do the loan. laugh
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#1900992 - 02/28/14 01:21 PM Re: APR TRIGGER Complianceking
RR Joker Offline
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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?
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#1901377 - 02/28/14 08:13 PM Re: APR TRIGGER Complianceking
Complianceking Offline
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West Coast
Thanks for your guidance.

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#1901398 - 02/28/14 08:44 PM Re: APR TRIGGER Complianceking
dblack Offline
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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.
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#1901487 - 02/28/14 10:37 PM Re: APR TRIGGER Complianceking
Complianceking Offline
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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?

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#1901533 - 03/03/14 02:09 PM Re: APR TRIGGER Complianceking
dblack Offline
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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 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
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