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#583057 - 07/13/06 05:33 PM APR Win software- Finance Charge understatement
complyaudit2 Offline
100 Club
complyaudit2
Joined: Apr 2002
Posts: 119
Good afternoon.

On the OCC APRWin software...
When you receive a Finance Charge understatement violation, which button do you select to determine reimbursment tolerance- o%, 1/8 or 1/4?

I have read all the Help topics relating to this issue, but I am still not comfortable.

Thank you. I can be PM'd if this would be easier discuss person-to-person.

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Lending Compliance
#583058 - 07/13/06 06:00 PM Re: APR Win software- Finance Charge understatement
Dan Persfull Online
10K Club
Dan Persfull
Joined: Aug 2002
Posts: 47,533
Bloomington, IN
If you want to avoid civil liability choose 0%. Otherwise choose 1/8% for regular transactions and 1/4% for irregular transactions. See Reg. Z's 226.22.
_________________________
The opinions expressed are mine and they are not to be taken as legal advice.

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#583059 - 07/13/06 06:06 PM Re: APR Win software- Finance Charge understatement
complyaudit2 Offline
100 Club
complyaudit2
Joined: Apr 2002
Posts: 119
Thank you. I had thought 0% was probably the most appropriate for the situation.

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