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#2269712 - 04/27/22 06:06 PM Re: APR in Ads MScarn6942
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For credit card advertising, I was running myself ragged in Reg. Z the past few days and kept going back and forth about the requirement to show a range. I checked some major credit cards online and the vast majority display a range, but I could not find this specifically stated in Reg. Z. The following could imply that a blended rate is necessary, though I could see it also being a reference to two different rates being used within the same year:

1. Corresponding annual percentage rate computation. For purposes of ยงยง 1026.60, 1026.40, 1026.6, 1026.7(a)(4) or (b)(4), 1026.9, 1026.15, 1026.16, 1026.26, 1026.55, and 1026.56, the annual percentage rate is determined by multiplying the periodic rate by the number of periods in the year. This computation reflects the fact that, in such disclosures, the rate (known as the corresponding annual percentage rate) is prospective and does not involve any particular finance charge or periodic balance.

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#2269724 - 04/27/22 07:13 PM Re: APR in Ads MScarn6942
rlcarey Offline
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I'm sorry. What are you referring to as a blended rate and why?
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#2269779 - 04/28/22 04:00 PM Re: APR in Ads MScarn6942
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Blended rate meaning a single APR that captures the various APRs that exist.

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#2269803 - 04/28/22 07:51 PM Re: APR in Ads MScarn6942
rainman Online
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The range of rates you are referring to on the application/solicitation disclosures is when the creditor offers multiple rates on the same product (i.e. risk based pricing). There's no blended rate for that. When the consumer actually opens the account, the account opening disclosure shows their actual rate. If there's a promotional rate for a particular period, the chart shows the promotional rate, how long it's in effect, and what the regular rate is (the current regular rate if it's a variable rate product).
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#2269995 - 05/03/22 07:09 PM Re: APR in Ads rainman
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Originally Posted by rainman
The range of rates you are referring to on the application/solicitation disclosures is when the creditor offers multiple rates on the same product (i.e. risk based pricing). There's no blended rate for that. When the consumer actually opens the account, the account opening disclosure shows their actual rate. If there's a promotional rate for a particular period, the chart shows the promotional rate, how long it's in effect, and what the regular rate is (the current regular rate if it's a variable rate product).

Yes, I just don't see where it is specifically noted in the advertising regulations. Is it because, in essence, if you disclose the APR for the product and different rates exist, then each separate rate IS the APR for that ad?

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#2269996 - 05/03/22 07:10 PM Re: APR in Ads MScarn6942
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My issue with that is Mortgage Loans have different rates as well based on borrower credit characteristics, but nobody goes around doing mortgage ads with a range of rates.

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#2270006 - 05/03/22 08:36 PM Re: APR in Ads MScarn6942
rainman Online
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If it's a "solicitation" to which 1026.60 applies, then that's your answer. If it's not, and it's just regular advertising, then nothing says you have to disclose a range. Some lenders advertise the range as opposed to advertising rates "as low as" the lowest rate for UDAAP/UDAP reasons.

Advertising a blended APR would not be accurate, because there is no such thing in open-end lending. But the same would be true for mortgages. If you offered a risk priced mortgage, you wouldn't advertise a "blended" APR that covered the different rates. The "blended" APR only applies when there are multiple rates that will apply to the same person's loan.
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#2270050 - 05/04/22 07:14 PM Re: APR in Ads MScarn6942
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@Rainman -- thank you for your input. This was helpful and solidifies my understanding.

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#2270463 - 05/16/22 03:31 PM Re: APR in Ads MScarn6942
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For closing costs, such as prepaid interest, does it just come down to picking a representative extension of credit and using that?

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