Sorry if this is a dumb question. But, all of our consumer loans have the same rate and APR. Mgmt says the reason is #1 we have no fees therefore nothing gets added into APR. #2 No balloon payments. #3 Mgmt says if there was an unusual payment stream, we are assuming we would still be within the tolerance. So, our loan doc system for just consumer loans is set to pull the Interest rate the MSR inputs over into the APR box on the TIL. Mgmt says examiners spent alot of time on these loans a few years ago but couldn't find any out of tolerance. IS this ok?!?!

As long as you can determine that the Amount Financed and payment schedule are properly computed, in an interest-only loan, the APR should compute out to be the same as the interest rate (unless you are increasing the interest rate by playing the 365/360 calendar game).