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Subject: Compliance Policy
Date: February 24, 2010
To: Chief Executive Officers and Compliance Officers of All National Banks, Federal Branches and Agencies, Department and Division Heads, and All Examining Personnel
Description: Revised Home Mortgage Disclosure Act Examination Procedures
The Office of the Comptroller of the Currency recently revised the electronic version of the "Home Mortgage Disclosure" booklet of the Comptroller’s Handbook.
The Federal Reserve Board amended Regulation C (12 CFR 203) by revising the definition of a rate-spread loan. The OCC is changing its examination procedures to include the new definition. Institutions must now report the rate spread between the annual percentage rate (APR) and the average prime offer rate for a comparable transaction as of the date the interest rate is set, if the spread is equal to or greater than 1.5 percentage points for first-lien loans, or equal to or greater than 3.5 percentage points for subordinate-lien loans.
Another change involves Home Mortgage Disclosure Act (HMDA) disclosure statements. These statements are no longer mailed to HMDA reporting institutions. Instead, financial institutions must download these statements from the Federal Financial Institutions Examination Council Web site.
Please direct questions to your supervisory office or the Compliance Policy Department at (202) 874-4428.
/signed/Ann F. Jaedicke