Skip to content
BOL Conferences
Thread Options
#1211886 - 07/03/09 02:10 PM APR Accuracy and Finance Charge Tolerance
Al Bankher Offline
100 Club
Joined: Nov 2007
Posts: 126
Sweet Home Alabama
Can anyone explain to me in layman's terms if or how the finance charge tolerance comes into play in verifying the accuracy of the APR?

Return to Top
Lending Compliance
#1212492 - 07/04/09 12:30 AM Re: APR Accuracy and Finance Charge Tolerance Al Bankher
Richard Insley Offline
10K Club
Richard Insley
Joined: Oct 2000
Posts: 10,203
Toano, VA
FC tolerance has no impact on APR accuracy. It can cause an understated APR to be excused from reimbursement, however. Search on "cross tolerance" and you'll find a few discussions of this concept.
_________________________
...gone fishing.

Return to Top
#1217642 - 07/15/09 07:04 PM Re: APR Accuracy and Finance Charge Tolerance Richard Insley
Game On Offline
Platinum Poster
Joined: Jul 2001
Posts: 566
Marietta, GA
The more I read the more confused I get! This is the first comment that seems to clear it up some.

PLEASE tell me if I am on the right track here:
Assume all are mortgage or dwelling secured loans.

1. You have a loan secured by a dwelling and the F/C is under disclosed $95. The APR is understated by .150% (regular transaction)

The F/C is okay but the APR is within tolerance.

Would you redisclose without reimbursement or would you redisclose with reimbursement since the APR was over? (Even though the F/C is within tolerance)?

2. Say you have a loan where the F/C is overdisclosed by $200
and the APR is overdisclosed by .150

Would you redisclose or do anything else?

3. A prepaid charge of $75 is not disclosed as part of the Finance Charge. The APR is underdisclosed 0.032% which is below the 1/8 of 1%
Do you just send a new disclosure- do you send anything at all?

Return to Top

Moderator:  Andy_Z