Impact of fee disclosures on HMDA reporting

Answered by:

Question:

The changes to HMDA are not effective until January 1, 2018, so what is the fee concern related to HMDA at this time?

Answer:

Among other items, the current HMDA LAR includes a rate spread, which is calculated by comparing the APR to the Average Prime Offer Rate. Fees placed in the wrong category leads to an incorrect finance charge, which leads to an incorrect APR, which leads to an incorrect rate spread.

Learn more about Jack’s webinar Untangling the Web of Fee Disclosures.