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#2238489 - 06/23/20 02:47 PM Reg Z - APR
Working From Home Offline
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Joined: Oct 2009
Posts: 257
If a borrower asks for the rate on an existing loan they already have with us, are we required to quote the APR or can we provide the rate?

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Lending Compliance
#2238490 - 06/23/20 02:49 PM Re: Reg Z - APR Working From Home
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 83,371
Galveston, TX
They have specifically asked what interest rate they are being charged on a current loan? Tell them the interest rate.
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#2238491 - 06/23/20 03:13 PM Re: Reg Z - APR Working From Home
Working From Home Offline
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Joined: Oct 2009
Posts: 257
Yes, they are just asking for the rate. So no requirement under Reg Z to also state the APR?

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#2238492 - 06/23/20 03:26 PM Re: Reg Z - APR Working From Home
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 83,371
Galveston, TX
It is not an advertisement or a quote. It is a loan servicing question.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#2238494 - 06/23/20 03:27 PM Re: Reg Z - APR Working From Home
Working From Home Offline
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Joined: Oct 2009
Posts: 257
Excellent. Thanks

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#2238496 - 06/23/20 04:17 PM Re: Reg Z - APR Working From Home
Richard Insley Offline
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Richard Insley
Joined: Oct 2000
Posts: 10,180
Toano, VA
Section 1026.2(a)(2) -- Advertisement means a commercial message in any medium that promotes, directly or indirectly, a credit transaction.

You are not promoting a credit transaction which has already occurred.
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