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#2203757 - 01/23/19 08:44 PM HOEPA vs HMDA Rate Spread Calculator
Katherine Offline
Member
Joined: Aug 2017
Posts: 62
Hello, I am posting this on the HMDA thread because this thread gets more love than HOEPA. For calculating the rate spread for the HOEPA high cost APR test, can I just use the HMDA calculator? The site notes that the calculation is different, but if I populate the calculator right, can't I just use it to see the spread and so long as it's under 6.5, I'm good?

Here's the calculator I am referring to.

https://ffiec.cfpb.gov/tools/rate-spread

Thank you.

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#2203771 - 01/23/19 10:05 PM Re: HOEPA vs HMDA Rate Spread Calculator Katherine
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 78,958
Galveston, TX
If you separately calculate the APR generated for the HOEPA test (it may not be what is on your CD depending on the loan type), then yes, you can use it for that purpose.
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