I am curious what others are going to do in regards to the date the interest rate is "set" for comparison to the average prime offer rate. When you look at one of their tables, the interest rate can flucturate enough within a couple-of-days period to affect the 1.5 and 3.5 reportable percentage point spreads. Historically, we have been using the settlement date
to determine our HMDA rate spreads. Our Mortgage Department has suggested changing it to the actual quote date the loan officer uses to possibly minimize any higher-priced mortgages....... what do you think?

Thanks,

Lisa

We are actually considering using the date on our in house approval form, but then I also thought maybe we should use the date of early disclosures (if apply).....haven't found anything that specifically specifies......

"If no lock-in agreement is executed, then the relevant date is the date on which the institution sets the rate for the final time before closing."

So, that means when you make a commitment (internally or externally) to make the loan at a specific rate. If you allow rates to float until closing - then the closing date is your date for applying the thresholds. You should probably develop some standard way to document this fact.

We just added a "rate lock date" blank to our internal underwriting forms. It was the simplest method we could come up with for getting the LO's to document a date the rate was "set" without having to add a separate form.