You're supposed to use the APR as of the date the rate was last set.
This is not correct. You use the date the interest rate was last set for comparison to the APOR as of that date but you must use the APR disclosed at consummation for that comparison.
To determine whether
the rate spread meets this
threshold, use the average
prime offer rate in effect for the
type of transaction as of the
date the interest rate was set,
and use the APR for the loan,
as calculated and disclosed to
the consumer under ยง 226.6
or 226.18, as applicable, of
Regulation Z (12 CFR part 226).
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The opinions expressed are mine and they are not to be taken as legal advice.