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New Rate Spread Calculator-APOR Spreadsheet

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With the new rate spread calculator, I am wondering if the APOR spreadsheet will it no longer be updated with each Monday? Also, I am getting conflicting answers within the forum: as a small servicer, is there an exception to the threshold of 3.5% on first liens or does the rule apply across the board whether you are a small creditor or not: 1.5% for first lien and 3.5% for subordinate liens to determine the HPML status?

The new CFPB calculator is updated accordingly. There is no small servicer exemption for determining HPML status.

First published on 03/10/2019

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