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#2073987 - 04/13/16 10:04 PM APRWIN Validity
RustyShackleford Offline
Member
Joined: Sep 2015
Posts: 92
I'm struggling reconciling APRWIN with TRID. First, the Total of Payments doesn't match between APRWIN and the box on page 5 of the CD. Second, all of my APRWIN APR calculations are showing an understated (not usually a violation) disclosed APR. We checked the APR on one loan in two different origination systems, and came up with the same APR (understated by APRWIN analysis). Do we have to do something different when entering data into APRWIN now that TRID is in full swing?

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TRID - TILA/RESPA Integrated Disclosures Rule
#2073991 - 04/13/16 10:47 PM Re: APRWIN Validity RustyShackleford
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 79,618
Galveston, TX
Well, the definition of Total of Payments for TRID loans has changed since the OCC developed APRWIN. Will they update it, I doubt it. However, all you have to do is add the Total Loan Costs from Section D and any Prepaid Interest and Mortgage Insurance from Section F, Line 2 & 3 (if any) and Mortgage Insurance from Section G, Line 2 (if any) to the total of payments from the APRWIN program and you have your number.

Second, I have reviewed several hundred TRID loans and use APRWIN all the time and have never had a APR issue if you are using the correct calculation methods. If all of your APRs are understated, the first thing I would be looking at is how you have all of your fees coded on your LOS as to whether or not they are actually prepaid finance charges. If your Amount Financed is also off from your manual calculations, there in lies your problem. Also, without an amortization schedule that supports the LE or CD it is virtually impossible to use APRWIN unless you have a fixed rate loan. All of my banks have been trained to include an amortization schedule with their loan documentation. Nothing has changed regarding how an APR is calculated.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#2073993 - 04/13/16 11:02 PM Re: APRWIN Validity RustyShackleford
RustyShackleford Offline
Member
Joined: Sep 2015
Posts: 92
Thank you. I'm looking at fixed rate loans, the amount financed matches, the disclosed finance charge and the calculated finance charge matches as well. So, I'm guessing that I need to look at how the fees are coded on our LOS to see what's contributing to the difference. I appreciate your time!

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#2073994 - 04/13/16 11:08 PM Re: APRWIN Validity RustyShackleford
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 79,618
Galveston, TX
Feel free to post some examples and maybe we can help.
Last edited by rlcarey; 04/13/16 11:08 PM.
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#2074193 - 04/14/16 09:10 PM Re: APRWIN Validity RustyShackleford
RustyShackleford Offline
Member
Joined: Sep 2015
Posts: 92
We drew up a test loan to use as an example (details below).

Loan Amount: $100,000
Interest Rate: 4.5%
Monthly P&I: $506.69
Loan Date: 4/15/2016
First Payment Due: 5/1/2016
Amount Financed: $98,800.74
Disclosed APR: 4.586%
Disclosed Finance Charge: 83,607.66
APRWIN APR: 4.6186%
APRWIN Finance Charge: $83,607.66

Why do the APRs differ between our LOS and APRWIN?
Prepaid Finance Charges ($1,199.26): 1% origination fee, $2 flood monitoring, and $197.26 prepaid interest.

We also have the following fees on the test loan:
Appraisal/Evaluation: $600
Credit Report: $30
Flood Certification: $12
Title-Lender's Title Insurance: $575
Recording: $105

I appreciate any time and help you can give in advance!

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#2074208 - 04/14/16 10:52 PM Re: APRWIN Validity RustyShackleford
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 79,618
Galveston, TX
I think you are going to have to ask your LOS processor how they are calculating the APR, because they are definitely doing something different. Who is it?
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#2074214 - 04/14/16 10:59 PM Re: APRWIN Validity RustyShackleford
RustyShackleford Offline
Member
Joined: Sep 2015
Posts: 92
Compliance 1 Mortgage. We'll start digging into it. Thanks again for your help.

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#2074472 - 04/18/16 03:23 PM Re: APRWIN Validity RustyShackleford
Dan Persfull Offline
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Dan Persfull
Joined: Aug 2002
Posts: 46,832
Bloomington, IN
I just ran 3 test loans in C1 Mortgage. I had no issues with APRWin.
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The opinions expressed are mine and they are not to be taken as legal advice.

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#2074507 - 04/18/16 04:30 PM Re: APRWIN Validity RustyShackleford
RustyShackleford Offline
Member
Joined: Sep 2015
Posts: 92
Thanks, Dan. I'm not sure where our problem is yet, but hopefully I can get it squared away soon.

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#2074602 - 04/18/16 11:05 PM Re: APRWIN Validity RustyShackleford
RustyShackleford Offline
Member
Joined: Sep 2015
Posts: 92
I have an update and two new questions. I have learned that we have C1Mortage configured to use the US Rule method.

Question 1: Would the US Rule method contribute to the problem described above?

Question 2: Am I double-counting prepaid interest by having it deducted from the Amount Financed and entering the Odd Days Interest in the payment schedule option (is this contributing to the understated APR)?

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#2074722 - 04/19/16 08:00 PM Re: APRWIN Validity RustyShackleford
Cheli Offline
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Cheli
Joined: May 2013
Posts: 919
Wow...RustySHackleford, we are having the same exact problem, and operate under ComplianceOne Mortgage too. I have been going crazy trying to figure it out with WKFS. They are stating that I am inputting the payment stream incorrectly..
It got to a point where they stated it "must be a glitch" in that particular loan...but it's not...Our software is constantly over-stating the APR.
We also have the US Rule method set up in Admin.

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#2074978 - 04/21/16 01:39 PM Re: APRWIN Validity RustyShackleford
Dan Persfull Offline
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Dan Persfull
Joined: Aug 2002
Posts: 46,832
Bloomington, IN
We also have the US Rule identified in C1 Mortgage and I am not having any issues with my disclosures matching APRWin's output.

APRWin:

Account Information: make sure you have the proper category checked. Regular APR or Construction Loan.

Loan Information - enter the amount financed, the disclosed APR and the disclosed Finance Charge (from page 5 of the CD). Make sure you have installment loan and Loan Secured by Real Estate or Dwelling checked.

Payment Schedule - for the first payment stream enter the payment amount and number of payment. Click the Calendar button and enter the note date and the first payment date - click OK. Repeat for any additional payment streams EXCEPT you do not need to go to the calendar for additional payment streams.
_________________________
The opinions expressed are mine and they are not to be taken as legal advice.

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#2074999 - 04/21/16 02:32 PM Re: APRWIN Validity RustyShackleford
Dan Persfull Offline
10K Club
Dan Persfull
Joined: Aug 2002
Posts: 46,832
Bloomington, IN
I ran the following through C1 Mtg.

Loan Amount: $100,000
Interest Rate: 4.5%
Monthly P&I: $506.69
Loan Date: 4/15/2016
First Payment Due: 5/1/2016
Amount Financed: $98,800.74
Disclosed APR: 4.586%
Disclosed Finance Charge: 83,607.66
APRWIN APR: 4.6186%
APRWIN Finance Charge: $83,607.66

Why do the APRs differ between our LOS and APRWIN?
Prepaid Finance Charges ($1,199.26): 1% origination fee, $2 flood monitoring, and $197.26 prepaid interest.

We also have the following fees on the test loan:
Appraisal/Evaluation: $600
Credit Report: $30
Flood Certification: $12
Title-Lender's Title Insurance: $575
Recording: $105

My results were as follows:

360 @ $506.87
Loan Amount: $100,000
Amount Financed: $99,170.60
APR: 4.590%
APR Fees: $829.40
Prepaid Odd Days Interest: ($172.60)
Number of Odd days: -14
Total Finance Charges affecting APR: $829.40
Total FC: $83,302.60

Ran these results through APRWin and the APR came back as 4.5895%.
_________________________
The opinions expressed are mine and they are not to be taken as legal advice.

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#2075022 - 04/21/16 03:37 PM Re: APRWIN Validity RustyShackleford
RustyShackleford Offline
Member
Joined: Sep 2015
Posts: 92
Dan et. al:

Thanks for the time and consideration on this. The mistake was mine, as Dan pointed out above. The first payment due date is 6/1/2016, and the APR balanced out with this change. I can't say how many times we combed through the data and overlooked this each time. So, I apologize for the false alarm and I thank you all for your time in the discussion. Have a great day, everyone!

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#2075074 - 04/21/16 06:17 PM Re: APRWIN Validity RustyShackleford
Cheli Offline
Platinum Poster
Cheli
Joined: May 2013
Posts: 919
Yes - I wasn't entering in the correct payment stream(s). I was having issues with our USDA loans.

Thank you, Dan!

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#2086231 - 06/30/16 08:06 PM Re: APRWIN Validity RustyShackleford
Jan94 Offline
Platinum Poster
Joined: Mar 2001
Posts: 828
USA
I'm having some difficulties with a construction only loan and appears to be with the construction interest. Not sure what is missing. The loan is a fixed rate, 6 month term, 5 mo. interest only with a final payment.

Input:
Commitment $399,641.08
Annual Simple Interest Rate 5.09%
Prepaid Finance Charge $301.00

Construction phase - actual days/365
# days - 182
Date of loan: 12/31/2015
First payment: 1/31/2016

Construction interest calculated (APRWIN) - $5,071.50

Closing Disclosure
Page 1
Loan Amount - $399,641.08
Interest Only Payments - $1,727.65
Final Payment - $401,313.00

Page 5
Total Payments - $410,794.56
Finance Charge - $10,443.98
Amount Financed - $399,340.08
Annual Percentage Rate - 5.229%

APRWIN Output
APR - 5.4002% (disclosed 5.229%)
FC - $5,372.50 (disclosed $10,443.98)
AF - $399,340.08 (matches CD)
Total Payments - $404,712.58 (disclosed $410,794.56)

It doesn't show anything understated or in violation; does show the last payment of principal & interest due at maturity is $399,641.08 (the principal only) - Anyone see something I'm not considering? Thank you for the assistance!

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#2086264 - 06/30/16 08:50 PM Re: APRWIN Validity RustyShackleford
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 79,618
Galveston, TX
Your LOS calculated interest on the whole amount for 182 days. Your interest only payment should have been $845.25.
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#2086463 - 07/01/16 07:12 PM Re: APRWIN Validity RustyShackleford
Jan94 Offline
Platinum Poster
Joined: Mar 2001
Posts: 828
USA
I've asked for confirmation from the LOS, but I did the following calculation but not coming up with your payment amount (or even the one we disclosed). You say it calculated on the whole amount for 182 days (which is the term of the loan). What am I overlooking? Appreciate the help!

Amortization Schedule
$399,641.08 at 5.09% interest
with 6 monthly payments
Interest-Only for 5 months (0.42 years)
Total Payments: $409,811.92 Total Interest: $10,170.84

Payment 1 1,695.14 0.00 1,695.14 399,641.08
Payment 2 1,695.14 0.00 1,695.14 399,641.08
Payment 3 1,695.14 0.00 1,695.14 399,641.08
Payment 4 1,695.14 0.00 1,695.14 399,641.08
Payment 5 1,695.14 0.00 1,695.14 399,641.08
Payment 6 401,336.22 399,641.08 1,695.14 0.00

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#2086473 - 07/01/16 07:21 PM Re: APRWIN Validity RustyShackleford
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 79,618
Galveston, TX
$399,641.08 X .0509 / 365 days x 182 Days / 2 (per Appendix D) = $5,071.50 / 6 = a $845.25 monthly interest payment. You assume that half the amount of the loan is outstanding for the term of the loan.

Your LOS calculated interest on the full loan amount, that is why your monthly interest payment amount is twice what it should be.
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#2087402 - 07/11/16 04:12 PM Re: APRWIN Validity RustyShackleford
Compliance504 Offline
Platinum Poster
Joined: Dec 2008
Posts: 697
Tennessee
Thank you so much for this thread.....this is VERY helpful!

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#2088141 - 07/14/16 10:06 PM Re: APRWIN Validity RustyShackleford
Cheli Offline
Platinum Poster
Cheli
Joined: May 2013
Posts: 919
Hi - I have my very first "**VIOLATION** that came up in APRWin...and I am not sure exactly what to do... :-/

It states:

APR violation understated by: .2851

Finance charge is understated by $1,540.80

When I click on the "Reimbursement" button, it states:

Lump Sum / Payment Reduction Method Payments 1-1 ($5.48)

Lump Sum Method: Payments 1 - 180 ($756.65)

The loan closed on May 27th. They just made their 1st payment.

What amount does my lender have to reimburse by? I have not been trained on this part, so please forgive me if this answer is suppose to be obvious :-/

Thank you!

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#2088149 - 07/15/16 01:43 AM Re: APRWIN Validity RustyShackleford
rlcarey Offline
10K Club
rlcarey
Joined: Jul 2001
Posts: 79,618
Galveston, TX
Did the right of rescission apply?
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#2088239 - 07/15/16 02:43 PM Re: APRWIN Validity RustyShackleford
Cheli Offline
Platinum Poster
Cheli
Joined: May 2013
Posts: 919
Yes, Randy, right of rescission applies.

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#2088240 - 07/15/16 02:45 PM Re: APRWIN Validity RustyShackleford
Cheli Offline
Platinum Poster
Cheli
Joined: May 2013
Posts: 919
I just realized I did not convey information correctly.

The loan closed on 5/23/2016- The right of rescission date is 5/27/2016. I used 5/27/2016 in APRWin...

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#2088245 - 07/15/16 02:52 PM Re: APRWIN Validity RustyShackleford
rlcarey Offline
10K Club
rlcarey
Joined: Jul 2001
Posts: 79,618
Galveston, TX
I order not to extend the RofR for three years you have to get the finance charge error to less than $100.
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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