Our Loan Origination Software will take the total of interest paid for the life of loan and round it up to a whole dollar amount and then calculate the TIP from there. Is this acceptable. While I don't find any guidance regarding this in 1026.37(l), there is some mention of minor variations in 1026.17. But that addresses whole cents, not dollars, is that the same?
1. Minor variations. Section 1026.17(c)(3) allows creditors to disregard certain factors in calculating and making disclosures. For example:
i. Creditors may ignore the effects of collecting payments in whole cents. Because payments cannot be collected in fractional cents, it is often difficult to amortize exactly an obligation with equal payments; the amount of the last payment may require adjustment to account for the rounding of the other payments to whole cents.