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.
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?
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.
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.
_________________________ Kathleen O. Blanchard, CRCM "Kaybee" HMDA/CRA Training/Consulting/Mapping The HMDA Academy www.kaybeescomplianceinsights.com
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?