Nothing has changed. For a variable-rate loan, the term is the initial, fixed-rate period (i.e. the period until the first schedule rate reset).

Why can't you use the CFPB rate spread calculator for HPML and High-Cost purposes? It's calculating a rate spread from the APR/APOR which you can then use to determine if it is a HPML or High-Cost. Sure, you have to do a little basic math and know the triggers, but it gets you the answer you need, right?

There is no real reason not too. As long as you are calculating the APR for high cost mortage purposes currently. It is not always the APR on your disclosures .

I am an idiot......but what????

If you are not making a fixed rate loan, the APR is calculated for the high cost mortgage test different than for the APR disclosure on the TRID disclosures.

1026.32(a)(3) Determination of annual percentage rate. For purposes of paragraph (a)(1)(i) of this section, a creditor shall determine the annual percentage rate for a closed- or open-end credit transaction based on the following:

(i) For a transaction in which the annual percentage rate will not vary during the term of the loan or credit plan, the interest rate in effect as of the date the interest rate for the transaction is set;

(ii) For a transaction in which the interest rate may vary during the term of the loan or credit plan in accordance with an index, the interest rate that results from adding the maximum margin permitted at any time during the term of the loan or credit plan to the value of the index rate in effect as of the date the interest rate for the transaction is set, or the introductory interest rate, whichever is greater; and

(iii) For a transaction in which the interest rate may or will vary during the term of the loan or credit plan, other than a transaction described in paragraph (a)(3)(ii) of this section, the maximum interest rate that may be imposed during the term of the loan or credit plan. {C}

Oh yes....right.

Maybe this will help: "New Rate Spread Calculator – What HMDA and Non-HMDA Banks Need to Know"

https://www.bankerscompliance.com/new-rate-spread-calculator-hmda-non-hmda-banks-need-know/

One sentence from the last paragraph of the link you provided states:

"The old calculator will still work because it’s based on the date the rate was set, not when the final action date occurred. So, if your rate set date was prior to January 1, 2018, you could still use the old tool, but that is only for a short period of time."

We identified a discrepancy between the APOR fixed rate spread table from 2017 and 2018. With a rate lock date of 11/13/2017 and a 7 year term, the old rate table provides an APOR of 3.58% and the new rate table provides an APOR of 3.55%. Is this expected OR should both tables provide the same APOR? Now that we have to report the rate spread regardless of value, we have a discrepancy of 0.03%.

Any thoughts?