Our loan department perpares the HMDA information from Lasor Pro to be imported into Questsoft. My question is when its a construction/perm loan for the rate spread information how is this reported?

In the Questsoft system we can enter the introductory rate of 12 months and then the loan term of 72 months, along with the ARP rate the rate spread is correct. However, the loan department and the upper management want the information reported as 12 month introductory rate and the loan term as 84 months, with the APR this throws off the rate spread, This has been a lenghly discussion and it was mentioned that the examiner had never caught this in the past and want to continue to report it that way.

Is there a correct way to report the construction /perm loans rate spread accurately in Questsoft for the HMDA LAR?

I strongly feel that the rate spread for these would make a difference and that it should reflect a correct rate spread reported to the LAR.. But if I'm missing something in the way that it is entered in Questsoft - then its a learning experience.

How is that throwing off the rate spread? For variable rate loans the inputs are rate set date, first change, and APR. None of those change if you change the term.

The term SHOULD include the construction period.

The term does include the construction period . Thats the issue - the 84 months is the construction phase and term. Once you add the 12 month intro that is what is throwing it off.

If the loan has a 12 month construction phase, then a 72 month permanent phase, and the rate can first change when it converts at 12 months, then you would report loan term: 84 months, introductory period: 12 months, and rate spread would be using the calculator with 1 year to first adjustment.

What is the issue?