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#1827976 - 06/26/13 07:34 PM Include any unearned portion of the old FC...
Likes to Comply Offline
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Joined: Nov 2008
Posts: 1,109
In the mountains
If our loans are simple interest loans, when refinanced, there shouldn't be any unearned portions of an old finance charge that needs to be added to the finance charge of the new obligation...Right?

Is there anything else I need to consider?

Thanks in advance for your help!
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#1828011 - 06/26/13 08:12 PM Re: Include any unearned portion of the old FC... Likes to Comply
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 83,393
Galveston, TX
How can there be unearned portions of interest on a simple interest note?
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#1828063 - 06/26/13 09:23 PM Re: Include any unearned portion of the old FC... Likes to Comply
Likes to Comply Offline
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In the mountains
Well, I guess there really isn't, but I started to mix things up in my mind when reading about precomputed finance charges in the Fed Exam Manual.

Would you provide me with an example of a finance charge that may have unearned portions outstanding when refinancing a loan and that would need to be included in the finance charge on the new disclosure?

Please excuse me, but I really have no idea what I'm looking for...
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#1828081 - 06/26/13 10:14 PM Re: Include any unearned portion of the old FC... Likes to Comply
rlcarey Offline
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rlcarey
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Galveston, TX
Well, considering I have not seen a loan in a bank that included precomputed finance charges since probably the 70's, I am a little at a loss to provide you a current day example.

Your first statement in your original post is correct. There are no unearned finance charges on simple interest notes.



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#1828118 - 06/27/13 11:57 AM Re: Include any unearned portion of the old FC... Likes to Comply
Likes to Comply Offline
Diamond Poster
Joined: Nov 2008
Posts: 1,109
In the mountains
That explains my confusion...I was born in the 70's and have only been in banking the last 10 years smile

I'm looking for something that isn't a practice anymore.

Thanks for your help!
Last edited by Likes to Comply; 06/27/13 11:58 AM.
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#1828135 - 06/27/13 01:21 PM Re: Include any unearned portion of the old FC... Likes to Comply
hgliii Offline
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Posts: 574
Comply, I went to a bank in the mid 80's that charged a $50.00 finance charge to be collected on last payment. They did not use it as pre-paid FC, because they said it was not collect until final payment.
FDIC did not see it that way. That is what the rule was addressing.
IMO.

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#1828154 - 06/27/13 01:48 PM Re: Include any unearned portion of the old FC... Likes to Comply
Richard Insley Offline
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Richard Insley
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Toano, VA
Earned and collected are not always the same thing.
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