Good Afternoon,

For some reason my LAR is reporting NA for Rate Spread on an Investment Property being used as collateral for a consumer purpose loan. Am I incorrect in thinking we should be reporting a Rate Spread in this situation?

If it is a consumer purpose loan than the rate spread is to be reported.

That is what I was thinking.....I have no idea why it is pulling as NA on my LAR. Time to talk to IT!

Thanks very much Dan!

(12)(i) For covered loans and applications that are approved but not accepted, and that are subject to Regulation Z, 12 CFR part 1026, other than assumptions, purchased covered loans, and reverse mortgages, the difference between the covered loan's annual percentage rate and the average prime offer rate for a comparable transaction as of the date the interest rate is set.

I'm with you...if the loan is subject to Reg. Z, you need the rate spread (unless you're exempt as a small creditor, like my bank).

Or what Dan said....he was quicker.

I am assuming it is an origination or an approved but not accepted. Depending on the action taken the rate spread may not be applicable.