What date is the rate considered to be "set" when an investor that makes a credit decision prior to closing, and thus has reporting responsibility for a loan, originates the loan through a broker, as discussed in staff comment 1(c)-2?

Compliance > Regulation C - HMDA > FFIEC FAQs
Q:  What date is the rate considered to be "set" when an investor that makes a credit decision prior to closing, and thus has reporting responsibility for a loan, originates the loan through a broker, as discussed in staff comment 1(c)-2?
 
A:  The last date the investor set the rate with the broker, not the date the broker set the borrower's rate.
 

This can be found in FFIEC’s FAQs on HMDA-related questions, which can be found at:  http://www.ffiec.gov/hmda/faq.htm

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