APR disclosure accuracy: CareBridge, Q3

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For a sample of loans originated in the quarter, confirm each disclosure labels the APR and shows it prominently, then recompute the APR from the note and compare. Jul 1 to Sep 30. 2,940 closed-end loans originated; a random sample of 25, with the APR recalculated from each note. Regulation Z · 12 CFR 1026.17(a), 1026.18(e), 1026.22(a) · High risk · Closed-end installment loans.

Findings · 0 of 1 decided

1. Loan 88412: APR disclosed 17.99%, recalculated 18.24%

Initial TILA disclosure, Loan 88412: "ANNUAL PERCENTAGE RATE 17.99%"

Recalculated from the note's payment schedule with the FFIEC APR tool: 18.24%. The difference (0.25 percentage point) is outside the one-eighth of 1 percentage point tolerance for a regular transaction (12 CFR 1026.22(a)(2)).

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Tasks

T-801 · Opened Sep 30 · APR disclosure accuracy · CareBridge · quarterly v1