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IR Disclosed in Promissory Note is Incorrect

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If the interest rate disclosed in a promissory note is incorrect (it is lower than what is actually being charged), is that a Reg Z problem? What if the TILA disclosure is within tolerance and is considered correct, could this then be an issue with UDAAP?

The interest rate quoted in the note is the contracted rate. You must charge that and only that rate. It isn't incorrect. You charging more than what you legally agreed to is the problem. If the Reg Z disclosures shows something else, it is also wrong.

Is that a UDAAP issue? Sure. You're charging more than what you legally agreed to charge.

First published on 10/30/2016

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