We have a file where the APR came up as 0.00 on the final CD. The note and LE both had an APR. Has anyone heard or know where the reg states reimbursement can be waived if APR is O on CD but was on the Note showing interest rate?

What would be best way to cure this?

How is an APR disclosed on a note?

The Administrative Enforce Guidelines are below.

Violations Involving the Non-Disclosure of the APR or Finance Charge

1. In cases where an APR was required to be disclosed but was not, the disclosed APR shall be considered to be the contract rate, if disclosed on the note or the Truth in Lending disclosure statement.

2. In cases where an APR was required to be disclosed but was not, and no contract rate was disclosed, consumers will not be required to pay an amount greater than the actual APR reduced by one-quarter of one percentage point, in the case of first lien mortgage transactions, and by one percentage point in all other transactions.

3. In cases where a finance charge was not disclosed, no adjustment will be ordered.

Mistyped meant APR was on LE. Thanks!

Curing is one issue, discovering what made it happen and if there are more are also part of the corrective actions.