To determine the rate spread for HMDA reportable loans - For non locked in loans - to calculate the rate spread - I've been using the CD Issue date - list on the Closing Disclosure. This to my understanding is the "set rate for the final time" prior to the closing date . I've just been informed that is not correct.
For the NON Locked loans - what date is considered the final date set???

Did you change the rate between the time you issued the initial CD and the final CD? If not and you reserved the right to change the rate prior to issuing the initial CD, why would that not be the correct date?

If you were informed that this is not correct, then I hope whoever told you that also told what date you were suppose to use.

No the rate was not changed from the time it was issued to final CD.

The only other option that I see is if the rate is set at loan approval. Some banks do that too. In this stable interest rate environment, that might be happening also. It really comes down to your internal procedures for setting the rate and exactly when it happens.

We lock our rate at application, however from time to time something comes up with title search and we end up having to do a rate extension.

My question is what would be the date that we use to test the APOR? I have always used the date at application
because that is the date the rate was set, the extension is not changing the rate just moving out the date.

The last time the rate was set was when the lender and the borrower entered into a rate extension agreement.