Answer:
APR rate spread testing for HMDA, HPML & HOEPA is based on the APR disclosed to the consumer at consummation.
First published on BankersOnline.com 4/25/11
Closed End 1st Mortgage Residential Loans
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Question:
Our Lending area performs an APR test for the purposes of borrower interest underwriting. When testing an APR by using an APR from the TIL, should the APR come from the initial or early TIL or from the Final TIL? We have heard that use of the APR should reflect when the loan is consummated.
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