Average Prime Offer Rate (APOR)
The Average Prime Offer Rate (APOR) is a rate that is derived from average interest rates, points, and other loan pricing terms currently offered to consumers by a representative sample of creditors for mortgage loans that have low-risk pricing characteristics. It is published weekly by the Federal Reserve Board and is used as a benchmark to determine if a loan is a Higher Priced Mortgage Loans (HPML) or to distinguish between Safe Harbor and Rebuttable Presumption (QM) status for Qualified Mortgage (QM)s [12 CFR § 1026.35(a)(2)].
Significance in Mortgage Lending
APOR is crucial for several regulatory determinations under Regulation Z:
- Higher-Priced Mortgage Loans (HPMLs): A loan is generally considered an HPML if its Annual Percentage Rate (APR) exceeds the APOR for a comparable transaction by a specified threshold (e.g., 1.5 percentage points for first-lien mortgages). HPMLs are subject to additional disclosure and appraisal requirements.
- Qualified Mortgages (QMs): For QMs, the relationship between the loan's APR and the APOR determines whether the loan receives a conclusive presumption of compliance (safe harbor) or a rebuttable presumption of compliance with the Ability-to-Repay (ATR) Rule Rule.
- If the APR is below the APOR plus 1.5 percentage points (for first-lien loans), it generally qualifies for safe harbor.
- If the APR exceeds this threshold but remains within certain limits (e.g., up to 2.25 percentage points above APOR for first-lien general QMs), it qualifies for a rebuttable presumption.
The APOR provides a standardized, objective benchmark for assessing the pricing risk and regulatory classification of mortgage loans.
Source material
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