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#2180128 - 05/30/18 02:24 PM HMDA Question
dac Offline
100 Club
Joined: Sep 2009
Posts: 234
When completing the HMDA data collection do we report the permanent information for the rate and introductory or do we have to count the construction period and rate as an introductory.

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#2180135 - 05/30/18 02:36 PM Re: HMDA Question dac
Adam Witmer Offline
Power Poster
Joined: Sep 2010
Posts: 2,643
From the commentary to 1003.4(a)(21):

1. Interest rate—disclosures. Section 1003.4(a)(21) requires a financial institution to identify the interest rate applicable to the approved application, or to the covered loan at closing or account opening.
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Adam Witmer, CRCM

All statements are my opinion, not those of my employer, and should not be taken as legal advice.
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#2191897 - 09/07/18 12:50 PM Re: HMDA Question dac
Cbigun Offline
100 Club
Joined: May 2016
Posts: 158
What about when you have a 0% intro period of 3 or 6 months, then it goes to ex: 3.5%. You can't enter 0%, which is the interest rate at the time of application or account opening. Do you report 3.5 since that is the rate that will be charged after the initial "free" months?

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