[kcco]

I have been told by examiners if a loan rate is set in one year but the final action doesn’t take place until the next year..to report NA for the rate spread. Is this correct? If so, can you direct me to the area in the guide/Reg that relates to this? Thanks

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[rcooper]

Neither Reg C nor the HMDA Guide give this as a reason for using N/A for the rate spread. Here are the reasons to us N/A according to Appendix A in Reg C
(https://www.ffiec.gov/hmda/pdf/2013guide.pdf):

b. If the loan is not subject to Regulation Z, or is a home improvement loan that is not dwelling-secured, or is a loan that you purchased, enter “NA.”
c. Enter “NA” in the case of an application that does not result in a loan origination.
and
e. If the difference between the APR and the average prime offer rate is less than 1.5 percentage points for a first-lien loan and less than 3.5 percentage points for a subordinate-lien loan, enter “NA.”

Here’s a link to information on an Rate Spread of NA from the HMDA Rate Spread calculator: https://www.ffiec.gov/ratespread/oldcalchelp.aspx. Scroll down to “Rate Spread Equal to NA”.

[Author]

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