Question regarding the APR disclosed on a revised LE:

If a valid change in circumstance affects both a Zero tolerance fee and a 10% tolerance fee, but the 10% tolerance fee is only changing the total for that category by 5%:

We will issue a revised LE with the new correct Zero tolerance fee, but not change the 10% fee since it's not exceeding the threshold. Should the APR printed on the revised LE take into consideration the new 10% fee even though the original 10% fee is still listed on the LE or should it use that original fee in calculating?

Any help would be appreciated

Hi Questioning,

The way I understand it, nothing in the Regs say you can't update a fee even if it still falls within the 10%. It just won't reset your threshold to zero. As long as you have a way to track it, there is not reason why you couldn't update it.

Personal opinion only.