Hi Randy, I don't really understand your answer. I do not have to extend the right of rescission, but I have to have our lender reimburse the consumer until our FC is under $100? If so, I reimburse from the $1540.80 amount, correct?
So, we should rectify this by giving the borrower $1440.80?

:-/

Cheli,

Sorry, I got in a little bit of a hurry yesterday and off the top of my head gave you the wrong information.

I suggest you get with your legal counsel for a recommendation on whether or not you want to just eliminate the regulatory liability (reimburse to APR/finance charge tolerances per APRWIN) or if you want to eliminate any potential civil liability. If you choose civil, then in order to prevent the borrower from rescinding the transaction if you initiate foreclosure proceedings (there is no three year period on this rule), the threshold is $35 (See 1026.23(h)(2). Most Bank's just write a check for the full amount and be done with it.

Thank you, Randy. I appreciate your time and energy on this one!

HI, I am having the same APRWIN validity issues. If you have a bridge loan to purchase a personal residence that is for 9 month interest only how would you enter the information correctly into the OCC aprwin calculator. The way I am enter the information the APR shows it is out of tolerance on all are TRID loans which I do not believe they are. Would appreciate any information offered.

Example Information on Page 5 CD:
Total Payments: 255,596.67
Finance Charge 10,316.67
Amount Financed: 241,010.00
APR 5.677%
Then the remaining information needed:
Note date: 7-21-16
First interest only monthly payment due 8-21-16
Maturity 4-21-17
Pre-Paid Finance Charges: 2,990.00
Our section D Total loans costs our 4,270.00, no Prepaid Interest & Mtg. Insurance or Mortgage Ins.

what is the monthly payment amount?

it is interest only due monthly. On the CD in Loan terms It shows Monthly P&I 204.89 but it is not monthly P&I. When it is an interest only payment we use to either inter it as a single pay or go through the construction section in order to calculate it correctly but that's not working with TRID loans

sorry gave you the wrong payment amount CD shoes 828.93.

How would you enter information for a fixed interest, 9 month interest only payment, It is bridge loan and not a construction loan. I have tried regular apr and construction.

Under the regular APR with the interest only and balloon payment streams. If you are advancing the total amount, using Appendix D is going to cause you real problems.

Can I use APRWIN for a variable rate?

Sure why not?

Need help with APRWIN being a whole new world for me when trying to double check for reimbursement due to attorney fee of $250 not included with total of finance charges on CD.

I ran the following through APRWIN

Amount Financed: $552,96.59
Disclosed APR: 5.619%
Disclosed Finance Charge: $592,961.38 without attorney fee of $250 and $593,211.38 with attorney fee.

5/1 ARM with payment of $3,183.11 for 51 months after closing on 8/22/2017 and first payment due 10/1/2017.
Payments of $3,183.12 for 284 months
and final payment of $3,185.49 for month 360.
Ran numbers through APRWin and the APR came back as overstated both times? So reimbursement not required?

Curious to see if anyone else got different results.

Thanks!

Amount Financed: $552,96.59 - what's the correct amount financed?

Payments of $3,183.12 for 284 months
and final payment of $3,185.49 for month 360. - what are the payment amounts for payments 285 through 359?

Apologies for typos -

Amount Financed: $552,963.59

Payments of $3,183.11 for 60 months
then $3,183.12 for payments 61 through 359
and final payment of $3,185.49 for month 360.

Thanks,

What was the attorney fee for???

Payoff arrangements on behalf of the client. Borrower's attorney.

If you didn't require them to use an attorney for this, why is it a finance charge?

Previously informed that we required the payoff as a condition of loan so fee could not be excluded as finance charge under Reg Z.

Hello -

Any different APRWIN results out there for the following?:

Amount Financed: $552,963.59
Disclosed APR: 5.619%
Disclosed Finance Charge: $592,961.38 without attorney fee of $250 and $593,211.38 with attorney fee.

5/1 ARM after closing on 8/22/2017 and first payment due 10/1/2017 with payments of $3,183.11 for 60 months
then $3,183.12 for payments 61 through 359
and final payment of $3,185.49 for month 360.

APR came back as overstated both times? So reimbursement not required?

Thanks,

Anyone use the FFIEC APR tool ? I just inputted information, feedback came back as Potential Non Compliance, Total of Payments Understated. Trying to figure out how to clear/ remedy this Potential Non Compliance -- APR is accurate.

We cannot help you based on the limited information you provided. I have not had a problem with the FFIEC APR calculator, outside of the TIP on construction loans (not sure if they ever fixed that issue or not?).

The total of payments should equal all payments of principal, interest, mortgage insurance, and loan costs, as scheduled, through the end of the loan term.

Give us your inputs and we'll get to the bottom of it.

jacquelineann, did you resolve your issue?Sometimes the first step is verify the inputs to double check the output. Nobody wants to go to management with a problem like this as if it's systemic it could be really big, if it's a one-off it's an expensive lesson. But it damages one's credibility if the mistake was yours.

You have peers here ready to help. Richard wrote the book of Reg Z calcs- literally.