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#2260874 - 10/07/21 12:57 PM APR
SallyGirl Offline
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Joined: Aug 2014
Posts: 58
Can an 2.079% APR be advertised as 2.07% APR? Or, must it be advertised as 2.08% APR?

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Marketing
#2260897 - 10/07/21 07:28 PM Re: APR SallyGirl
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 77,591
Galveston, TX
You need to read the commentary to 1026.14(a) - Comment 2, if this is opened-end credit. For closed-end there is nothing similar - you just have to worry about whether or not that would be deceptive. .
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#2260912 - 10/08/21 12:25 AM Re: APR SallyGirl
Richard Insley Online
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Richard Insley
Joined: Oct 2000
Posts: 10,007
Toano, VA
Discussions of the "annual percentage rate" in Sections 1026.14 and 1026.21 are the closest thing to a definition of the term. Included in these discussions is the standard 1/8% (0.125%) accuracy tolerance. If I'm arguing the accuracy of your advertisement with a regulator, I would insist that the +/- 1/8% tolerance applies to all quotations of the APR, including advertised rates. Internally however, I would never allow lenders or marketing to round down for ads and oral quotations. As Randy rightly observes, it's best not to flirt with something that can be considered a deceptive practice.
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