I am not that impressed with the APR calculator.

https://www.ffiec.gov/calculators.htm

Thanks Randy!

Just saw this - so... is this supposed to be replacing APRWin? Is this what examiners will be using?

Press Release
For Immediate Release April 16, 2020

FFIEC Announces Federal Disclosure Computational Tools

The APR Computational Tool is designed to streamline the process by which examiners and financial institutions can verify finance charges and annual percentage rates included on consumer loan disclosures subject to the Truth in Lending Act and its implementing regulation, Regulation Z.

appears way easier than APRwin for construction loans anyways. ill have to test it more later with actual figures.

Hard to say. It does calculate the TRID total of payments and TIP - but it is clunky as heck to use and does not address restitution issues or even compare the disclosed APR and F/Cs disclosed.

The OCC has removed APRWin and APYWin from their website and now points to the FFIEC web tool.

The APR tool worked fine on a couple straight-up TRID loans we tested.

We tested two construction/permanent loans the new tool excluded the construction interest from the calculation of the TIP so we had a difference there. Anyone else seeing this?

I am struggling with getting this tool to work when there is mortgage ins on an FHA loan. Anyone else getting it to work? If yes, are you putting the UPMI fee and then just the monthly amount in the escrow? It works fine on the other loans but if MI is involved I get an understated error. Help!

Are you inputting all of the individual payment streams? The MI portion decreases on a yearly basis on an FHA loan.

I did not. I will try that and see if that helps. I am getting two different answers between APRWIN and FFIEC. APRWIN says I am overstated, but considered accurate because I don't believe it is a FC fee issue, and FFIEC says I am understated. I will try running the payment streams and see if that helps. Thank you for that suggestion.

Neither program is going to work, if you do not input the correct payment streams. FHA insurance runs either 11 years or the term of the loan, depending on the starting LTV.

Thank you! That made all the difference in the world. Haven't done much with FHA so it is a learning curve! Once again, you guys to the rescue! Thank you so much for the time you spend giving us help!

Mortgages with annual changes in the MI renewal premiums make for the toughest APR verifications. The monthly renewal fees are FCs, so you have to add them to the amounts of the P&I payments--which might also change in some types of FHA loans. Add all of these factors together and you end up inputting as many as 30 or 31 different payment streams in order to verify the FC and APR. If you have a volume of these loans and are burning up a lot of time running APRs, there are ways to reduce your precision, rely on the 1/4% APR tolerance, and save time.

Thank you Richard.

We tested two construction/permanent loans the new tool excluded the construction interest from the calculation of the TIP so we had a difference there. Anyone else seeing this?

today was the first chance I had to test a construction/perm loan and noticed the TIP was off. It took me a while to figure out where the error was.

You are correct. The calculator is wrong.

We had discontinued our single close construction loans prior to the new tool and are now resurrecting them. We have a question about inputting the days in the tool. Our construction phase is 6 months. Example being loan closes on July 1, 2021, 6 month construction brings us to January 1, 2022 end of construction period. We believe our first payment for permanent loan would be due Mach 1, 2022. Are we thinking correctly?

Your first payment on the permanent loan can be anything that you want it to be unless limited by State law or investor requirements.

Like Randy mentioned, could be. I've seen loans close in the 1st week of the month and the borrower wanted to continue paying the 1st of the following month. Borrowers got an interest credit at closing.

Another question as we work on our construction loan relaunch. We disclose per appendix D A.1 of part II, when testing the TIP it appears the FFIEC APR tool does not include the construction phase interest into the calculation. Our vendor is including it. Who is correct?

We felt because it states the following:

B. The creditor shall compute the estimated annual percentage rate as follows:

1. Estimated interest payable during the construction period shall be treated for computation purposes as a prepaid finance charge (although it shall not be treated as a prepaid finance charge for disclosure purposes).
2. The number of payment shall not include any payments of interest only that are made during the construction period.

Also:C. The creditor shall disclose the repayment schedule as follows:
1. For loans under paragraph A.1 of part II, other than loans that are subject to § 1026.19(e) and (f), without reflecting the number or amounts of payments of interest only that are made during the construction period. The fact that interest payments must be made and the timing of such payments shall be disclosed.

That the construction phase interest is not included for purposes of testing the TIP under A. 1, but the actual advance schedule does not follow that assumption. Wouldn't the TIP either be under or overstated if included?

Your vendor is correct. I personally have pointed this out to the CFPB several times and it has fallen on deaf ears.

It is heartening to know that the examining agencies will be using it.

Thanks RC