For the Rate Spread, will the "APOR" table still be found on the FFIEC's website?

If not, which site are we to use to double-check the rate spread?

I have seen no information to date on where the information will be posted.

After reading up on Rate Spread, it looks like they are saying that the FFIEC's site will continue to publish the tables.
(Let me know if you interpret that differently, please).



http://www.consumerfinance.gov/eregulations/1003-4/2015-26607_20180101#1003-4-a-12
Official Interpretation to 4(a)(12)
Comment 2 - Bureau Tables

The Bureau publishes on the FFIEC's Web site (http://www.ffiec.gov/hmda), in tables entitled “Average Prime Offer Rates-Fixed” and “Average Prime Offer Rates-Adjustable,” current and historic average prime offer rates for a wide variety of closed-end transaction types. The Bureau calculates an annual percentage rate, consistent with Regulation Z (see 12 CFR 1026.22 and Part 1026, Appendix J), for each transaction type for which pricing terms are available from the survey described in comment 4(a)(12)-1. The Bureau uses loan pricing terms available in the survey and other information to estimate annual percentage rates for other types of transactions for which direct survey data are not available. The Bureau publishes on the FFIEC's Web site the methodology it uses to arrive at these estimates. A financial institution may either use the average prime offer rates published by the Bureau or may determine average prime offer rates itself by employing the methodology published on the FFIEC Web site. A financial institution that determines average prime offer rates itself, however, is responsible for correctly determining the rates in accordance with the published methodology.

You can get the rate from the tables that they direct us to. Just remember that all spreads will be reported, including negative spreads (like with a discounted initial rate), not just spreads over certain %s.

Thank you Kathleen!

Anyone know if we will still be able to use the calculator (will it be updated?) or will we have to use the tables?

I emailed the FFIEC last week. Waiting to hear back from them. If they don't have the calculator updated by 1/1/18 then it seems we will have to use the tables and do our own math to double-check the Rate Spreads. Boooo.

Gah! That's what I was afraid of!

Our HMDA software (Questsoft) has a calculator built into it. It imports the tables as they are updated. I do spot check their accuracy each year prior to submission, but so far, no issues.

Just now received a reply back from FFIEC saying (basically) sorry you need to contact CFPB about that.
So...I forwarded it to the email address they provided, which was: HMDAHelp@CFPB.gov.
Now we wait...still...

Our LOSs have the calculator in them, and I have tested them in the past and they appear to be accurate.
I just like to have a nice online calculator to double-check periodically without having to look at a gazillion page spreadsheet.
Well at least we do have that option LOL.

For our data audit, my current plan is to still use the calculator, but to work backwards to check the spread. Basically, the auditor will enter 10 as the APR in the calculator (which should always give a spread) and enter the result into our excel audit template. Then a simple formula can convert that value to the actual APOR, subtract that from the APR, and use the result to compare to the spread on our LAR.

Not pretty, but quicker and less error prone than manually checking APOR sheets.

The CFPB's HMDA Help said the calculator was recently updated and to clear my cookies or try a different browser.
I did both and still get the "NA" result.
I emailed them a screen shot.

Can anyone else test it and see if it's working for them (ex: try a very low APR that you know would not exceed the HPML threshold - even better if you can test a NEGATIVE rate spread)?

Thanks!

Nope - Nadda

Same here. I tried on a computer that has never been to the site and still get NA.
The page says "Last modified: 09/15/2016" at the bottom.

Funny - I just got this response from CFPB yesterday evening:

"The CFPB's Rate Spread Calculator and Check Digit Tool will be available to financial institutions by January 1, 2018."

I would like to say I am surprised... hahaha