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Financial Services Law Insights and Observations
New York Financial Regulator Extends Subprime Calculation Temporary Order
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.