Thread Starter: Anonymous
Title: Re: APR out of tolerance (unintentionally)
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I would appreciate any and all input on a possible cure for this violation.
I realize I can not "un-do" this loan. I just want to address the issue before the examiners have the opportunity.
We are a small bank who only made two residential real estate loans last year. (We have since stopped completely) We "thought" we priced them to a point where they would not be considered to be a higher priced mortgage loan. The APR is out of tolerance, due to a prepaid finance charge. If I refund the prepaid finance charge (Flood Determination Fee), the APR is still out of tolerance, by .02%.
How do I mend this mistake?
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