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#2159674 - 01/09/18 01:27 PM CFPB Rate Spread Calculator
HallieK Offline
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HallieK
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Oklahoma
Has anyone tested the new rate spread calculator? I can not come up with the results that it shows. Is it not the APR minus the APOR?

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#2159675 - 01/09/18 01:32 PM Re: CFPB Rate Spread Calculator HallieK
rlcarey Online
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Yes - it doesn't work. Rumor had it that it was going to be fixed last Thursday - but nothing yet.

Everyone needs to inundate the HMDA Helpline with the proper complaints: hmdahelp@cfpb.gov

Don't forget to mention that the 2017 APOR figures in their tables do not match the tables originally published by the FFIEC.
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#2159748 - 01/09/18 04:58 PM Re: CFPB Rate Spread Calculator rlcarey
raitchjay Online
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Originally Posted By rlcarey

Everyone needs to inundate the HMDA Helpline with the proper complaints: hmdahelp@cfpb.gov

Don't forget to mention that the 2017 APOR figures in their tables do not match the tables originally published by the FFIEC.


Done.
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#2159828 - 01/09/18 07:56 PM Re: CFPB Rate Spread Calculator HallieK
HallieK Offline
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Can do and thank you

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#2159830 - 01/09/18 08:03 PM Re: CFPB Rate Spread Calculator HallieK
RR Becca Offline
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out of the frying pan...
Done.
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#2159927 - 01/10/18 03:22 PM Re: CFPB Rate Spread Calculator HallieK
RR Becca Offline
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RR Becca
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out of the frying pan...
Just received this reply:

Thank you for your question. We were dealing with a number of issues affecting the rate spread calculator. We implemented fixes for all of the known issues, with the exception of a remaining bug that returns incorrect rate spread values on loans with a 1 year loan term. We expect this to be resolved by the end of the week. As a result, the calculator should now be returning correct values for any loan term other than 1 year.

The current rate spread calculator produces results in accordance with the regulatory requirements of HMDA rule effective 1/1/18, which are different than the prior requirements. Rate spread calculation and reporting does not change based on lien status or interest rate thresholds under the current regulation. Lien status was only relevant for the prior reporting requirements due to the reporting threshold on subordinate lien loans being 3.5% versus 1.5% for first lien loans. The prior regulation stipulated that rate spread was to be reported NA unless it was greater than or equal to 1.5% on first lien loans or greater than or equal to 3.5% on subordinate lien loans. Therefore, the prior rate spread calculator reported NA if the calculation did not meet those thresholds. Given that these thresholds are eliminated in the current regulation, please use the current rate spread calculator to calculate the actual rate spread for all loans, both high priced and otherwise.

More information on reporting requirements can be found in section 1003.4(a)(12). of the regulation: https://www.consumerfinance.gov/eregulations/1003-4/2015-26607_20180101#1003-4-a-12”
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#2159929 - 01/10/18 03:48 PM Re: CFPB Rate Spread Calculator HallieK
rlcarey Online
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First paragraph is great - I guess they just felt they needed to throw a canned paragraph in that was irrelevant to the issue.
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#2159933 - 01/10/18 03:58 PM Re: CFPB Rate Spread Calculator HallieK
RR Becca Offline
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RR Becca
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out of the frying pan...
I thought that was a bit odd.
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You call it ADD. I call it multi-tasking.

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#2160213 - 01/11/18 08:26 PM Re: CFPB Rate Spread Calculator HallieK
HallieK Offline
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HallieK
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Oklahoma
Has anyone tries the calculator since they claimed to have fixed it. I am entering:

Action taken: 1
Fixed rate
Rate set: 1-2-2018
APR: 5.072
Loan Term: 5

Rate spread shows 1.482

If you pull the APOR table a 5 year fix rate shows as 3.5 so how can the spread be 1.482? What am I missing.

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#2160216 - 01/11/18 08:28 PM Re: CFPB Rate Spread Calculator HallieK
rlcarey Online
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Missing? Only your e-mail to hmdahelp@cfpb.gov
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#2160223 - 01/11/18 08:39 PM Re: CFPB Rate Spread Calculator HallieK
HallieK Offline
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HallieK
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Oklahoma
Already did that. I never got an answer on my last one. Maybe this time.

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#2160302 - 01/12/18 02:53 PM Re: CFPB Rate Spread Calculator HallieK
Dan Persfull Offline
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The APOR as 01/02/2018 is 3.59 for a 5 year term.

5.072 - 3.59 = 1.482
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#2160306 - 01/12/18 03:13 PM Re: CFPB Rate Spread Calculator HallieK
rlcarey Online
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That will teach me for not actually looking.
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#2160376 - 01/12/18 07:58 PM Re: CFPB Rate Spread Calculator HallieK
cgorham Offline
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Funny that their email said they have fixed all issues but 1 year terms, but you get this message when you type in a rate set date in the last week of 2017:
"We're sorry, the rate spread on entries with a rate set date between 12/25/17 and 12/31/17 cannot be calculated right now. We are working on an update to resolve the issue"

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#2160389 - 01/12/18 08:38 PM Re: CFPB Rate Spread Calculator Dan Persfull
HallieK Offline
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Oklahoma
The rate spread calculator is giving a spread of .922 (sorry I put the wrong spread earlier)

Their table also lists the APOR as 3.56

Still haven't heard back in response to my inquiry.

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#2160391 - 01/12/18 08:43 PM Re: CFPB Rate Spread Calculator HallieK
rlcarey Online
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You must be looking at a totally different table than Dan and I are looking at. The 5 year APOR on the fixed rate table is definitely 3.59. The calculator also produces 1.482 for me also. If you are getting a .922 response, you have the variable rate button checked.
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#2160392 - 01/12/18 08:51 PM Re: CFPB Rate Spread Calculator HallieK
Dan Persfull Offline
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If I check the variable button I too get the .922 rate spread.

The variable APOR for 1/2/18 is 4.15.

5.072 - 4.15 = .922
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#2160684 - 01/17/18 01:36 PM Re: CFPB Rate Spread Calculator Dan Persfull
HallieK Offline
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Oklahoma
This is what I get on the variable rate table:

Years to First Adjustment|1|2|3|4|5|6|7|8|9|10|
1/2/2017|3.6|3.56|3.57|3.57|3.56|3.56

You are right that I was on the variable rate.

This is what the fixed rate shows:

Term of Loan in Years|1|2|3|4|5|6|7|8|9|10|
1/2/2017|3.52|3.38|3.47|3.47|3.5|3.5|
Last edited by HallieK; 01/17/18 01:37 PM.
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#2160686 - 01/17/18 01:45 PM Re: CFPB Rate Spread Calculator HallieK
HallieK Offline
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HallieK
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Oklahoma
I am very confused. Where are you getting your figures from and the info above is straight off the CFPB Calculator.

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#2160693 - 01/17/18 02:27 PM Re: CFPB Rate Spread Calculator HallieK
rlcarey Online
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Those are the 01/02/2017 figures - I thought you were talking about 2018.
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#2160701 - 01/17/18 02:52 PM Re: CFPB Rate Spread Calculator HallieK
HallieK Offline
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HallieK
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Oklahoma
OK, my bad. Know it makes sense. Thank you so much

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