I spoke with Rod Alba at the ABA yesterday about several HMDA issues. He tells me the CFPB has their "doors open" for things that need to be amended, fixed, etc. Let me assure you, I gave him plenty of things to take to the CFPB. One of the things I mentioned was the rate spread calculator and how it's not working correctly. Rod tells me the CFPB is working on it and fixing several things. Randy C had pointed out in another post that the CFPB appeared to have changed the tables and the calculator was giving different results than it was earlier. Rod said he would take this to the CFPB and, if they made changes, they need to announce it so we can recalculate spreads we may have already done.
Stay tuned!