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#2158917 - 01/02/18 07:33 PM
Re: CFPB rate spread calculator
Whyisit
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Junior Member
Joined: Jun 2015
Posts: 26
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We were given 4 sets of files to choose from in consultation with your compliance officer - are you kidding! What have others done? Apparently we have the same vendor. We chose option #3 but none of them sounded much better than the others. I just hope this is solved by the end of the week.
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#2158918 - 01/02/18 07:35 PM
Re: CFPB rate spread calculator
rlcarey
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Junior Member
Joined: Apr 2014
Posts: 39
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The rate table has an APOR for a 5 year fixed with a rate set date of today as 3.59, however when you run that same data through the rate spread calculator the calculator is actually using a rate of 3.50.
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#2158921 - 01/02/18 07:53 PM
Re: CFPB rate spread calculator
Whyisit
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Member
Joined: Mar 2015
Posts: 89
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We were given 4 sets of files to choose from in consultation with your compliance officer - are you kidding! What have others done? I am thinking about choosing option 3 based on the FFIEC historic rates, I'm not sure how to verify the CFPB's accuracy. I will have IT change the dates to reflect the accurate posting and effective dates in the CSV file.
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#2158925 - 01/02/18 08:07 PM
Re: CFPB rate spread calculator
rlcarey
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Junior Member
Joined: Apr 2014
Posts: 39
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The rate table has an APOR for a 5 year fixed with a rate set date of today as 3.59, however when you run that same data through the rate spread calculator the calculator is actually using a rate of 3.50.
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#2158926 - 01/02/18 08:09 PM
Re: CFPB rate spread calculator
LaLendingLady
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10K Club
Joined: Jul 2001
Posts: 83,227
Galveston, TX
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The rate table has an APOR for a 5 year fixed with a rate set date of today as 3.59, however when you run that same data through the rate spread calculator the calculator is actually using a rate of 3.50. Well that seems to be a problem then - doesn't it I got the same results.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com
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#2158927 - 01/02/18 08:13 PM
Re: CFPB rate spread calculator
RR Becca
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Gold Star
Joined: Jun 2010
Posts: 257
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The CFPB rate spread calculator is just wrong under certain circumstances (a basic math check of their rate spread shows this), and the CFPB's historical (2017) APOR tables shows different entries for some of the 2017 values than what the FFIEC had previously published. The CFPB is going to publish new APOR tables on Thursday, which should hopefully be updated to correct their errors. (Fingers crossed).
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My opinion, take it for what its worth. Opinions expressed are my own and not those of my employer and are not legal advice.
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#2159004 - 01/03/18 03:27 PM
Re: CFPB rate spread calculator
RR Becca
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10K Club
Joined: Jul 2001
Posts: 83,227
Galveston, TX
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The spread is the spread regardless of lien status. This is for reporting HMDA data and is not an HPML testing calculator.
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#2159013 - 01/03/18 03:40 PM
Re: CFPB rate spread calculator
RR Becca
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Power Poster
Joined: Oct 2009
Posts: 9,088
OK
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Because rate spreads used to only be reportable based on the HPML rules....i.e., first lien got a 1.5 threshold, subordinate liens got a 3.5 threshold.....now the spreads are reportable no matter what they are, even negative spreads.
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#2159015 - 01/03/18 03:41 PM
Re: CFPB rate spread calculator
RR Becca
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Gold Star
Joined: Jun 2010
Posts: 257
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Lien status used to be relevant to rate spread for HMDA because it was only reported on certain HPML loans. For example, if the lien status on the HMDA loan equaled code 1 and the rate spread calculated was less than 1.5 percentage points, the result will be a rate spread was reported as 'NA' etc. That's been removed now that rate spread is reported on basically all HMDA reportable loans.
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My opinion, take it for what its worth. Opinions expressed are my own and not those of my employer and are not legal advice.
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#2159037 - 01/03/18 05:44 PM
Re: CFPB rate spread calculator
raitchjay
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Gold Star
Joined: Feb 2002
Posts: 319
NJ
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But, we still need to calculate the Rate Spread for Reg Z purposes using a lien position for compliance with those high-cost loan provisions when rates exceed 1.5 or 3.5 percentage points on a 1st or 2nd line. Therefore, the new "rate spread" calculator no longer calculates based on these factors, and ONLY for HMDA.
LOS systems still need to be able to calculate and identify HPML loans for Reg Z...the calculator tool in 2018 take that function away.
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#2159101 - 01/03/18 09:52 PM
Re: CFPB rate spread calculator
RR Becca
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Gold Star
Joined: Jun 2010
Posts: 257
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The HMDA rate spread calculator has never been used for Reg. Z testing (even the FFIEC website has a warning on it about this).
You're mixing up the rate spread calculator and the underlying APOR tables. The tables are used as part of the rate spread calculation, true, but those same tables are used to do Reg. Z testing. You still use the same underlying APOR value, you just use them in different tests at different times. So long as the LOS vendor has the APOR value, it should be able to do both tests.
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My opinion, take it for what its worth. Opinions expressed are my own and not those of my employer and are not legal advice.
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#2159108 - 01/03/18 10:06 PM
Re: CFPB rate spread calculator
GTS333
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Power Poster
Joined: Oct 2009
Posts: 9,088
OK
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So long as the LOS vendor has the APOR value, it should be able to do both tests. The key word there is "should". Getting pretty frustrated with my vendor.
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#2159118 - 01/03/18 10:22 PM
Re: CFPB rate spread calculator
RR Becca
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Gold Star
Joined: Jun 2010
Posts: 257
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Well, getting the APOR tables from the CFPB website into your LOS is another issue. Remember, without any warning the CFPB changed the file type of the APOR files, their location, and basically made their versions conflict with the APOR tables the FFIEC published in 2017, so the CFPB isn't exactly making it easy on vendors. Hang in there HMDA warriors, we'll get through this!
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My opinion, take it for what its worth. Opinions expressed are my own and not those of my employer and are not legal advice.
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#2159119 - 01/03/18 10:30 PM
Re: CFPB rate spread calculator
RR Becca
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Power Poster
Joined: Oct 2009
Posts: 9,088
OK
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I'm confused now...which is it? They gave plenty of warning...or they gave no warning?
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#2159123 - 01/03/18 10:37 PM
Re: CFPB rate spread calculator
RR Becca
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10K Club
Joined: Jul 2001
Posts: 83,227
Galveston, TX
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The only warning anyone had is if they clicked on the actual APOR tables on the CFPB website that came up about 7-10 days ago and saw the scramble of data.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com
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#2159515 - 01/06/18 04:28 PM
Re: CFPB rate spread calculator
GTS333
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Gold Star
Joined: Feb 2002
Posts: 319
NJ
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We'll have to change our method of calculating because, due to a serious problem with our LOS vendors consistency with the APOR tables, and our IT departments' flawed rules on allowing software systems to 'go out' and get updated tables, we have been going to the FFIEC's rate spread calculator (which up until the CFPB messed with it, was NEVER a HMDA spread calculator) to generate the REG Z RATE SPREAD. Without the FFIEC's previous tool, which ends as of 12/31/17, we have to manually calculate.
THE CFPB has essentially erased the RATE SPREAD calculator with their HMDA calculator - which still doesn't work as of this morning.
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My opinion is free: sometimes you get what you pay for; sometimes you get lucky.
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#2159516 - 01/06/18 06:15 PM
Re: CFPB rate spread calculator
RR Becca
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10K Club
Joined: Jul 2001
Posts: 83,227
Galveston, TX
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The FFIEC's rate spread calculator was always a HMDA calculator. I'm not sure what you mean?? Theoretically, the CFPB calculator is exactly the same, just that it will report the spreads regardless of the HPML limits.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com
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#2159850 - 01/09/18 08:50 PM
Re: CFPB rate spread calculator
RR Becca
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10K Club
Joined: Oct 2006
Posts: 14,390
Cheeseheadland
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So am I just dumb... can the APOR only be found on an individual basis if you run the calculator, and there is no more master table to view?
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#2159851 - 01/09/18 08:56 PM
Re: CFPB rate spread calculator
#Just Jay
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Junior Member
Joined: Apr 2014
Posts: 39
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APOR rate tables are available at the top of the page via hyperlinks in the second paragraph.
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#2160328 - 01/12/18 04:40 PM
Re: CFPB rate spread calculator
RR Becca
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Member
Joined: Sep 2015
Posts: 88
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This may have been covered already...put its a long post...IF a loan is variable...what do we put for the term? The first rate period before the rate changes...or the actual term?
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