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#2278751 - 12/13/22 09:26 PM APR Tool: overstated APR or user error
Live 2 Comply Offline
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Live 2 Comply
Joined: Sep 2009
Posts: 341
Ok so in testing a CD secured loan I am getting a potential noncompliance alert that the APR is overstated by .3784%

Amount Financed is $1000, Finance Charge is 132.80, Total payments are 1132.80 with annual percentage rate of 23.2916% date of loan is 4/1/22 with 1st payment at 5/4/22 and 12 payments of 94.40.
I thought our system had some sort of issue, but I have used other apr calculators and I am getting the same result that our LOS produced. I don't typically use this APR Tool so I am trying to figure out if I am doing something wrong. Thanks in advance.

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Lending Compliance
#2278755 - 12/13/22 10:12 PM Re: APR Tool: overstated APR or user error Live 2 Comply
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 83,364
Galveston, TX
If you have a one-year loan with a note amount of $1,000 at an interest rate of 23.2916%, how can you only have $132.80 of interest? That should be at least $232.92.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#2278757 - 12/14/22 12:00 PM Re: APR Tool: overstated APR or user error Live 2 Comply
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 83,364
Galveston, TX
Too late to edit my answer above, but I was thinking of an interest only loan. I actually ran the numbers and it appear to work for me. You say you are getting a potential non-compliance. Exactly what is it saying?

Disclosure Information - Output
Amount Financed
$1,000.00
Finance Charge
$132.80
Total of Payments
$1,132.80
Annual Percentage Rate
23.2916%
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#2278817 - 12/15/22 02:04 PM Re: APR Tool: overstated APR or user error Live 2 Comply
Live 2 Comply Offline
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Live 2 Comply
Joined: Sep 2009
Posts: 341
I figured it out. The note date should have been 4/4/22 but for whatever reason it was printed as 4/1/22 so when I did the calculation with the 3 days odd days interest, I received the alert.

I have another with a semiannual pay that I am getting the same message on. Amount financed 1500, Finance charge 297.10, Total Number of Payments 1797.10, and APR 19.053%. I have the actual APR showing 18.3381% with APR being overstated by .7149%

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#2278818 - 12/15/22 02:06 PM Re: APR Tool: overstated APR or user error Live 2 Comply
Live 2 Comply Offline
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Live 2 Comply
Joined: Sep 2009
Posts: 341
I forgot to post the rest of it. Loan date 7-15-22. Payment schedule was 1 payment of 24.25 on 1-15-23 and final payment on 7-15-23 of 1772.85

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#2278836 - 12/15/22 06:47 PM Re: APR Tool: overstated APR or user error Live 2 Comply
rainman Offline
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rainman
Joined: Nov 2004
Posts: 3,238
APR is correct at 19.053%. 18.3381 is the nominal interest rate IF interest is compounded at the time of the bizarre January payment of $24.25. If interest is not compounded at that time, nominal interest rate is 19.807%. But either way, the APR (which is derived from the total amount of interest and the timing of the payments) is the same: 19.053%.
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