Neither. Per Section 1026.14(b), you don't look at interest billed at all. The APR is determined by multiplying the periodic rate by the number of periods in a year. So the tolerance for this disclosure is really just whether you did your multiplication right. If the daily periodic rate is .027397%, the APR is 10.00% (or more accurately 9.9999%). The old "statement APR" that included non-interest finance charges and was calculated based on finance charges actually charged and account balances now only applies to HELOCs under 1026.7(a) and even then, it's optional.
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