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-12â€
_________________________
You call it ADD. I call it multi-tasking.