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#2117939 - 02/13/17 02:47 PM Rate Spread on Commercial Loan & HMDA
Red Raiders Offline
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Compliance Land
From time to time we have a HMDA reportable business purpose loan that gets disclosed on consumer docs; therefore, an APR is disclosed. In these cases where we have a business loan that discloses an APR, do we report "N/A" for Rate Spread or calculate based on the APR that was disclosed?
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#2117945 - 02/13/17 03:24 PM Re: Rate Spread on Commercial Loan & HMDA Red Raiders
C4C Offline
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Joined: Jan 2016
Posts: 23
See page 41 A-8 from the GIR. If the loan is not subject to reg Z, than you would report NA for your rate spread.

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