I have been told by examiners if a loan rate is set in one year but the final action doesn’t take place until the next year..to report NA for the rate spread. Is this correct? If so, can you direct me to the area in the guide/Reg that relates to this? Thanks
b. If the loan is not subject to Regulation Z, or is a home improvement loan that is not dwelling-secured, or is a loan that you purchased, enter “NA.”
c. Enter “NA” in the case of an application that does not result in a loan origination.
e. If the difference between the APR and the average prime offer rate is less than 1.5 percentage points for a first-lien loan and less than 3.5 percentage points for a subordinate-lien loan, enter “NA.”