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#35861 - 10/04/02 01:15 PM HOEPA APR Test
Anonymous
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Section 32 states to use "the yield on Treasury securities having comparable periods of maturity to the loan maturity as of the 15th day of the month immediately preceding the month in which the application for the extension of credit is received by the creditor,..."

The example given on the Federal Reserve Bank of Dallas web site http://www.dallasfed.org/htm/pubs/e-perspec/2002/2_2n.html specifically shows that you go to the H15 Federal Reserve Statistical Release, Treasury Constant Maturities with a comparable maturity to the loan, and look under the WEEKLY (FRI)tab.

This seems to be the weekly average. I have seen posted on a thread that you use the daily rate, not the weekly average. Does anyone know which is correct? Could it be that the Fed made a mistake in its example? Thank you.

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Lending Compliance
#35862 - 10/04/02 02:19 PM Re: HOEPA APR Test
Dan Persfull Offline
10K Club
Dan Persfull
Joined: Aug 2002
Posts: 47,532
Bloomington, IN
In reply to:

the yield on Treasury securities having comparable periods of maturity to the loan maturity as of the 15th day of the month immediately preceding the month in which the application for the extension of credit is received by the creditor,




We were told to use the daily rate at a workshop.
Last edited by dpersfull; 10/04/02 02:20 PM.
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The opinions expressed are mine and they are not to be taken as legal advice.

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#35863 - 10/04/02 02:24 PM Re: HOEPA APR Test
Gotwood Offline
Platinum Poster
Joined: May 2001
Posts: 715
I think it was an honest mistake on whoever created the example. I'm following the wording in the regulation. In the footnotes section of the H15 release it states: "Note: Weekly and monthly figures are averages of business days unless otherwise noted." The 5.34 rate quoted in the example is the weekly average ending March 15th. The reg doesn't say take an average, it says use the rate on the 15th.

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#35864 - 10/04/02 02:54 PM Re: HOEPA APR Test
Anonymous
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