If I have a decline I need to report and do a rate spread on a loan that is floating what do I use for a lock date to calculate rate spread???

I am confused. Why would you report a rate spread on a loan that did not originate?

I was told to have a FFIEC rate spread calcul;ation on every adverse action file...Is this not the case???

"1. Rate Spread. a. For a home-purchase loan, a refinancing, or a dwelling-secured home improvement loan that you originated, report the spread between the annual percentage rate (APR) and the average prime offer rate for a comparable transaction if the spread is equal to or greater than 1.5 percentage points for first-lien loans or 3.5 percentage points for subordinate-lien loans."

There is no rate on a decline. The loan was not originated.

No. Per the instructions 'enter NA in the case of an application that does not result in a loan origination'.

Edited to add: Darn postings, Kathleen's response wasn't showing up a minute ago.

I have heard of banks being cited for reporting rate spreads on loans that did not originate. Also, do not report spreads that are below the required levels. It's a matter of reporting what should be reported and being sure that you are not reporting what you shouldn't.

Yes anything that should not be there and is will be cited as an error and anything that should be there and is missing is an error.

It is all about data accuracy.