The financial institution I work for does car loans which are technically open-ended. I know that the APR is a trigger term but since we don't have any charges or fees I'm not sure what else we need to disclose besides maybe the possible rates which are fixed.

223.16 shows the floowing are required:

(i) Any minimum, fixed, transaction, activity or similar charge that is a finance charge under §226.4 that could be imposed.

(ii) Any periodic rate that may be applied expressed as an annual percentage rate as determined under §226.14(b). If the plan provides for a variable periodic rate, that fact shall be disclosed.

(iii) Any membership or participation fee that could be imposed.

For ii, would we need to list the possible range of rates that may apply since it says ANY PERIODIC RATE? A customer can get 2.99% with great credit but up to 8.0% with less than perfect credit. Should I list a range in the fine print?

Thanks

Double post.