Question & Answer

Question: Does a consumer loan rate sheet have to show additional disclosures if there is a triggering term?

Answer: First, the rate is a triggering term. So one answer to your question is yes.

But the answer really depends on whether you provide copies of the rate sheet to customers. If the document is for internal use only, to provide information to loan officers, then you would not need to include the triggered terms. You merely need to make sure that your loan officers know how to present the rate and APR. However, if you place the rate sheet in a consumer information packet, you would need to provide the additional information in the packet.

Copyright © 2001 Compliance Action. Originally appeared in Compliance Action, Vol. 5, No. 16, 1/01