On a fixed rate loan, I need help when looking at the APR Coverage test to determine if a loan is High Cost...
The Reg. says, "For a transaction in which the annual percentage rate will not vary during the term of the loan or credit plan, the interest rate in effect as of the date the interest rate for the transaction is set."

Am I supposed to be comparing APOR+6.5/8.5 to the INTEREST RATE of the loan or the APR of the loan??

To me, I read it to say Interest Rate, is that correct or WHAT AM I MISSING???

Just what the rule says - use the interest rate if it's a fixed rate. Sometimes a cigar is just a cigar.