HMDA – Issues with points – Date Rate Set impact

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  • #36333

    Could you please provide feedback on the scenario below?

    “Given the eventual interest rate of 2.25%, the Date Rate Set reported should have been 11/30/21 instead of 10/22/21.”
    This is what I sent the LOB.

    Their response was, “I disagree. The pricing was based on the original rate set date and the adjustment was simply to meet compliance issues with the points. Sometimes we do lender credits on CDs to meet compliance issues. That does not change the rate set date.”

    Are they correct? Because the eventual rate resulted based from the original rate locked via points, it is not a HMDA reportable (via Rate Spread) Date Rate Set event.


    It seems that the confusion revolves around using the interest rate or the APR. It is not clear to me from the information provided in the question what happened to the points, the interest rate and the APR. More explanation would be helpful. Regulation C states that the relevant date to use to determine the average prime offer rate for a comparable transaction is the date on which the interest rate was set by the financial institution for the final time before final action is taken (i.e., the application was approved but not accepted or the covered loan was originated).

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