Hi Jack…the aversion stems from the pricing options to pay down the interest rate via points being tied to the original/previous rate lock terms, so despite the affect to the “Net Rate” (decreased) at the time of later execution, the LOB interprets maintaining the original/previous lock’s Date Rate Set makes more sense and is in line with other regulatory guidance outside of HMDA (APOR and Rate Spread), not to mention pricing communications with Secondary Market investors. They believe the HMDA regulatory commentary doesn’t directly address this situation, despite our pointing out the examples were not the extent of Date Rate Set change considerations. They were just that…a couple of examples. We met and spoke on this again recently. One of them wants to check with LOS compliance contacts from their previous life elsewhere, and we are trying to have a meeting set up with an ABA mortgage compliance specialist. We definitely agree that it is most ideal if all regulatory guidance pertaining to one data element were perfectly aligned. We would prefer it…but our interpretation on this as it pertains to HMDA alone seems most accurate, and it appears others in the industry agree. I appreciate you feedback on this. Thanks!
