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#689315 - 02/20/07 01:01 PM Overstated APR
bgehres Offline
100 Club
Joined: Mar 2005
Posts: 126
I have a loan in which the APR was overstated due to a fee being included in the finance charge that shouldn't have been. This affected the APR enough so that the rate spread for HMDA is 3.02. Should we use the APR that was disclosed to the customer or what should have been the correct APR for the calculation?

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#689340 - 02/20/07 02:12 PM Re: Overstated APR bgehres
Dan Persfull Offline
10K Club
Dan Persfull
Joined: Aug 2002
Posts: 46,762
Bloomington, IN
For HMDA purposes you report the rate spread based on the APR disclosed at consummation. See page A-9 of the GIR.
The opinions expressed are mine and they are not to be taken as legal advice.

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