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BankersOnline.com Forums Dodd-Frank Final Rules Discussions HMDA Overhaul 2018 Rate Spread for HMDA
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#2251508 - 03/30/21 07:09 PM Rate Spread for HMDA
ADN Offline
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Joined: Mar 2007
Posts: 222
When compliance is auditing files for TRID and scrubbing HMDA data and, we have found a few files that the APR slightly off, but within Reg Z tolerance. Should we be reissuing CD's with the new APR and updating the HMDA rate spread? Our mortgage department is not wanting to go back and make these adjustments when they are within Reg Z tolerance.

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#2251533 - 03/31/21 11:45 AM Re: Rate Spread for HMDA ADN
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 83,364
Galveston, TX
What is done is done. You cannot go back and adjust either the APR or finance charge post closing.
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#2251745 - 04/02/21 03:36 PM Re: Rate Spread for HMDA ADN
Andy_Z Offline
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Andy_Z
Joined: Oct 2000
Posts: 27,750
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What's needed is to determine why there are variances and how the issue can be corrected.

If it's a matter of rounding it would be insignificant in my eyes, but if it's some systemic error and is consistently off, ask why. At times it is a difference in computation formulas, each of which is acceptable but these should be consistent in the bank.
Last edited by Andy_Z; 04/02/21 03:39 PM.
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