I am looking at 1026.37(o)(4)and I'm slightly confused.

Based on the Small Entity Guide it states to report the Loan Term in Whole dollars and not disclose the cents, but the section related to this field states that "it shall not be rounded, and IF the amount is a whole number then the amount disclosed shall be truncated at the decimal point.
Seems like a contradiction.

If the loan amount is 155,500.54; should it be disclosed as $155,500 or as the exact number. I realize that at least we wouldn't round it up to $155,501.

Any thoughts?

Thanks!!

You mention both "Loan Term" and "Loan Amount" in your question so I'll provide my take on both:

Loan Amount (Loan Estimate within the Loan Terms section - page 1):

Two decimal places ($5,000.75). Do not round. Truncate whole numbers at the decimal point ($5,000).

Loan Term (Loan Estimate top of page 1):

Maturity > or =; 24 Months:
The term to maturity must be disclosed in “years” followed by “months”

For example:
120 Month Loan = “10 years”
185 Month Loan = “15 yr. 5 mo.”


Maturity < 24 Months:
The term to maturity must be disclosed in “months” unless the total number of months are equal to an even year (i.e. 1 year).

For example:
6 Month Loan = “6 mo.”
16 Month Loan = “16 mo.”
12 Month Loan = “1 year”

Based on the Small Entity Guide it states to report the Loan Term in Whole dollars and not disclose the cents,

Can you give a page #? I couldn't locate this statement. The only statement I found similar is :

Dollar amounts must be rounded to the nearest whole dollar where noted in the regulation.

But this statement refers to "where noted in the regulation". So you would have to refer to the section of the regulation dealing with the section of the LE you are completing to see how the figure is to be rounded. Most figures on the LE will be rounded.

If the Loan Amount is $155,500.54 then you disclose it on the LE as $155,500.54. If the Loan Amount is $155,500.00 then you would disclose it on the LE as $155,500.

Thank you guys...
After reading it for the hundredth time, it finally made sense. Crazy how one litte work like "if" can confuse the brain!

Dan ~ page 18 section 2.2.2 Loan Terms.

Ahh....found it... thanks.

Loan Amount (if the amount is in whole dollars, do not disclose cents)(§ 1026.37(o)(4)),


Yes, if you overlooked the "if" the statement could be confusing when reading the other rounding requirements.

Could I ask someone for clarification, please?
On page 11 of the CFPB TRID Forms Guide under Rounding it says:
“If an amount is required to be rounded but is composed of other amounts that are not required or permitted to be rounded, use the unrounded amounts in calculating the total and then round the final sum.”

So, let’s say in the Projected Payments Section the principal and interest payment is disclosed as $852.49 and there is mortgage insurance of $132 (rounded from $132.49). Would I
1) add $852.49 and $132.49 to get $984.98 and then round it to $985 OR
2) add $852.49 and $132 to get $984.49 and then round it to $984?

The way I interpreted that statement you would calculate the total using your #1 example.

Thank you, Dan. I appreciate your help!