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Financial Services Law Insights and Observations

New York Financial Regulator Extends Subprime Calculation Temporary Order

HUD Subprime

Lending

On August 30, the New York Department of Financial Services extended through September 30, 2013 a temporary order directing New York lenders to disregard the mortgage insurance premium changes effectuated by HUD Mortgagee Letter 2013-04 when calculating APR and fully-indexed rates for purposes of determining whether a loan is a “subprime home loan” under the New York Banking Law.