It has always been my understanding that Reg Z does not apply to credit extended by a US bank to a nonresident alien, as mentioned in the Commentary under "Foregn Applicability". I am trying to discuss this with my auditor and I think it would be helpful to her if I had an article or another document expanding on this. I cannot find anything; can someone point me to something?

Thanks

You can't expand on the Commentary unless you get a legal opinion. I think the Commentary to Section 1(c) answers the question nicely & that's all your auditor needs to see.

Thanks, Richard. By the way, I love my APR/APY calculator. We hope to see you at a SFCA seminar soon.