what date do you use when the application date is one thing
(ex 1-1-04) but the rate/loan approval date is another (ex:
7-1-04) 12-15-03 or 6-15-04. This loan would really be NA as it is for rental & therefore not subject to Rez Z but had it been what would we had needed to check.
thanks

For HOEPA you use the rates as of the 15th of the month preceding the month the application was received.

What about the #2 "Date the rate was set". That makes it sould that if the bank didn't approve or set the rate for say 2 weeks , that would be the date. Please clarify.

Don't confuse HOEPA and HMDA requirements for calculating the rate spread.

Which one are you inquiring about, HOEPA or HMDA?

The rate spread section on HMDA is where i saw to use the date the rate was set from instruction n completing hmda, however in the Federal Register,final rule,it said to use the month preceding the month in which the application was recevided by the institution. & the apr for the loan.
I'm sure I'm making this harder than should be, but I want to be sure that we get this correct.
thanks again for your help