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#14674 - 04/03/02 03:46 PM Reg. Z - APR Tolerance

I am looking for a concise description of the APR tolerances under Reg. Z?

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General Discussion
#14675 - 04/03/02 05:35 PM Re: Reg. Z - APR Tolerance
JMB Offline
Joined: Mar 2002
Posts: 59
There is a pretty detailed article in the ABA Compliance Magizine from March/April 1998 titled "Compliance Alert: Restitution Redux: The Tila Reimbursement Rules After The Rodash Amendments". It is written by by Alan J. Dombrow, CRCM, and Walter E. Zalenski.

Since you probably would not have that unless you have way too much storgage space, or access to a regulatory service, you might go to the FDIC-Compliance Examination Manual Appendix E -- Truth In Lending Reimbursement. While not as "fun" to read, it is pretty detailed.

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#14676 - 04/04/02 02:48 PM Re: Reg. Z - APR Tolerance
Howard Lax Offline
Gold Star
Howard Lax
Joined: Jan 2002
Posts: 478
Bloomfield Hills, Michigan
There is an earlier article in ABA Bank Compliance by Alan Dombrow from 1996 or 1997 that had a flow chart on the last page of the issue showing the TILA finance charge tolerances. I remember this one because I co-authored the "More Alligators in Swamp" article in that issue.
Howard A. Lax Lipson, Neilson, et. al. Bloomfield Hills, MI

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#14677 - 04/04/02 07:28 PM Re: Reg. Z - APR Tolerance
Richard Insley Offline
10K Club
Richard Insley
Joined: Oct 2000
Posts: 10,097
Toano, VA
Don't forget to factor in the TIL enforcement policy tolerances.
...gone fishing.

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#14678 - 04/04/02 07:54 PM Re: Reg. Z - APR Tolerance
CalifDreamin Offline
Diamond Poster
Joined: Mar 2002
Posts: 2,240
Far from Calif
Here is the link to the OCC TIL Handbook which talks not only about tolerances, but about restitution.

There is also a detailed discussion of it in the Commentary for section 226.22.
The opinions expressed are mine and do not necessarily reflect those of my employer

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