In preparation for this year’s HMDA submission, RiskExec recommends that you verify the Rate Spreads on all of your records and confirm that they are correct.

In 2020, there were two instances where the CFPB had an error in the APOR tables on their website. It is important to note that these tables are used to calculate the Rate Spread in your RiskExec HMDA records.  However, the RiskExec system will only maintain the most current set of APOR tables and will automatically update the tables if and when the APOR tables are updated on the CFPB website. 

The RiskExec team has connected with the CFPB on several occasions in an effort to receive guidance on how to handle this situation.  Unfortunately, the CFPB has not offered any clear recommendations on which rates to use for loans that were locked in during the period when the APOR tables were in error.  Therefore, RiskExec recommends that each institution review all of the loans that were locked in or booked on the dates in the ranges listed below. Please evaluate all Rate Spreads in preparation for your institution’s submission.

The first incident occurred during the release of the tables on July 17, 2020, for the APOR Rates for Fixed Rate Loans.  Please see below: