Posted By: dac
HMDA Question - 05/30/18 02:24 PM
When completing the HMDA data collection do we report the permanent information for the rate and introductory or do we have to count the construction period and rate as an introductory.
Posted By: Adam Witmer
Re: HMDA Question - 05/30/18 02:36 PM
From the commentary to 1003.4(a)(21):
1. Interest rate—disclosures. Section 1003.4(a)(21) requires a financial institution to identify the interest rate applicable to the approved application, or to the covered loan at closing or account opening.
Posted By: Cbigun
Re: HMDA Question - 09/07/18 12:50 PM
What about when you have a 0% intro period of 3 or 6 months, then it goes to ex: 3.5%. You can't enter 0%, which is the interest rate at the time of application or account opening. Do you report 3.5 since that is the rate that will be charged after the initial "free" months?