The new Average Prime Rate Offer (APOR) tables released by CFPB are now available for download to FIPCO's Compliance Concierge. The recent CFPB APOR tables were in a different format than those FFIEC has released in the past. FIPCO converted the APOR tables into a usable format and performed additional testing before releasing it days before other service providers were able to do the same. APOR tables are used in several compliance related calculations.

Compliance Concierge will continue to calculate the HPM Rate Spread and Maximum HOEPA APR.  FIPCO uses the FFIEC/CFPB APOR tables, but not their calculator.

FIPCO cautioned users that CFPB’s new Rate Spread Calculator appears to be incorrectly calculating rate spreads for transactions with a Rate Set Date between 12/25/2017 and 12/31/2017. It is possible that other date ranges in CFPB’s Rate Spread Calculator could be affected. It appears CFPB is now working to fix this problem. FIPCO suggests users who wish to verify Compliance Concierge’s HPM Rate Spread calculation manually calculate it by referring to the applicable table. The Fixed Rate APOR table may be found by clicking here.  The Adjustable Rate APOR table may be found at by clicking here.