Date for FFIEC Calculator (In-House Loan)

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Question:

1.) What date do you use when using the FFIEC calculator to determine a higher priced loan (in-house loan) Is it the application date or is it the date that the loan is to be closed. 2.) This loan is a jumbo loan so would the same rule apply for a different threshold of 2.5 instead of 1.5% even though it is an in-house loan?

Answer:

1. The date for the rate lock is the "date the interest rate is set". Refer to 226.35(a). It's not necessarily the application date or loan closing date. It could be any date between these two. The loan officer needs to document this date as it can vary per loan.

2. The jumbo loan exemption is only for the escrow requirement. If you have a first lien jumbo loan that has a rate >1.5% above the APOR, it is still a HPML. If the rate is between 1.5 - 2.49% above the APOR, you don't have to apply an escrow to the loan, however.

First published on BankersOnline.com 5/30/11