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#1974848 - 11/06/14 06:03 PM Early to final TIL
Anonymous
Unregistered

The more I read the more opinions I see. In regards to the APR/Finance charge tolerance form the early to final til, I understand it as The Final APR cannot exceed the early by more than .125%. The final Finance charge cannot exceed the early by more than $100. Understatement for both on the final is deemed ok.

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#1975373 - 11/07/14 09:54 PM Re: Early to final TIL Anonymous
Aggs Offline
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Aggs
Joined: Nov 2009
Posts: 1,331
Hoosier Country
We've had many discussions on this in the past. Here is one example:
http://www.bankersonline.com/forum/ubbthreads.php?ubb=showflat&Number=1411335

I've always taken the stance that if the APR varies by more than the allowed tolerance of .125% - either way - we redisclose. Some may have a different interpretation.
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CRCM + CAMS = certified compliance nerd

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#1975375 - 11/07/14 10:01 PM Re: Early to final TIL Anonymous
BrianC Offline
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Joined: Nov 2004
Posts: 5,920
Illinois
As I always say, there is greater risk in under-disclosing than over-disclosing. When in doubt, disclose.
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