"Given the eventual interest rate of 2.25%, the Date Rate Set reported should have been 11/30/21 instead of 10/22/21."
This is what I sent the LOB.
Their response was, "I disagree. The pricing was based on the original rate set date and the adjustment was simply to meet compliance issues with the points. Sometimes we do lender credits on CDs to meet compliance issues. That does not change the rate set date."
Are they correct? Because the eventual rate resulted based from the original rate locked via points, it is not a HMDA reportable (via Rate Spread) Date Rate Set event.