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#14674 - 04/03/02 03:46 PM Reg. Z - APR Tolerance
Anonymous
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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
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JMB
Joined: Mar 2002
Posts: 59
Michigan
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
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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.
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#14677 - 04/04/02 07:28 PM Re: Reg. Z - APR Tolerance
Richard Insley Offline
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Richard Insley
Joined: Oct 2000
Posts: 10,097
Toano, VA
Don't forget to factor in the TIL enforcement policy tolerances.
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#14678 - 04/04/02 07:54 PM Re: Reg. Z - APR Tolerance
CalifDreamin Offline
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CalifDreamin
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.
http://www.occ.treas.gov/handbook/til.pdf

There is also a detailed discussion of it in the Commentary for section 226.22.
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