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#2266253 - 02/11/22 11:09 PM HMDA - Issues with points - Date Rate Set impact
Help! Compliance Offline
Member
Joined: Oct 2012
Posts: 94
San Antonio, TX
"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.

???

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#2266254 - 02/11/22 11:46 PM Re: HMDA - Issues with points - Date Rate Set impact Help! Compliance
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 79,926
Galveston, TX
"and the adjustment was simply to meet compliance issues with the points."

You are going to have to explain what the LOB is talking about. What adjustment and for what compliance reason? You need to provide a lot more information to understand the issue.
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