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#2050110 - 11/17/15 06:28 PM APR Disclosure
jhoch Offline
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Joined: Nov 2014
Posts: 66
Do banks have to disclose APR on commercial loan transactions?

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Lending Compliance
#2050116 - 11/17/15 06:38 PM Re: APR Disclosure jhoch
Richard Insley Offline
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If "commercial loan" means an extension of credit to a corporation (or other business entity) or a loan to one or more consumers for a business purpose (as defined in Section 1026.3), then Regulation Z does not require the calculation or disclosure of an APR. Although unlikely, you should also determine that state law and requirements of any third parties do not impose such a standard.
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#2050157 - 11/17/15 08:12 PM Re: APR Disclosure jhoch
jhoch Offline
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Posts: 66
Thats what I thought but wanted to make sure I wasn't missing something. How about if a commercial customer (yes corporation or other biz entity) asks what the APR is on the loan? I know we don't have to disclose it but from a customer experience perspective what is your thought on what to tell them?

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#2050163 - 11/17/15 08:52 PM Re: APR Disclosure jhoch
Rocky P Online
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Florida
Most commercial customers know or care little about an APR,
IMHO, tell them the note rate.
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#2050211 - 11/18/15 03:49 AM Re: APR Disclosure jhoch
Richard Insley Offline
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Richard Insley
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The concepts "Annual Percentage Rate", "Finance Charge", and "Amount Financed" did not exist prior to enactment of TILA. They were invented exclusively to carry out the purposes of TILA and TILA does not (with minor exceptions) apply to anything except consumer credit.
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#2050212 - 11/18/15 11:28 AM Re: APR Disclosure jhoch
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
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If not in a state, like Georgia, that requires calculation of an APR for commercial transactions, I would explain the it does not apply and that even if it did, their APR would be their interest rate because there would be no adjustments.
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#2050223 - 11/18/15 02:29 PM Re: APR Disclosure jhoch
jhoch Offline
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Posts: 66
Thank you all.

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#2050235 - 11/18/15 03:03 PM Re: APR Disclosure Kathleen O. Blanchard
Richard Insley Offline
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Richard Insley
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Toano, VA
Originally Posted By Kathleen B
Georgia requires calculation of an APR for commercial transactions....
That's interesting. Is the calculated rate labeled "Annual Percentage Rate"? If so, is there a disclaimer that the calculation does not conform with Appendix J?
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