Reply To: HMDA – Issues with points – Date Rate Set impact


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).

  • This reply was modified 6 months, 1 week ago by jholzknecht.