We were cited in an exam for just stating the the abbrev "APR" in an open end loan ad on our website. As I read the reg Z you can either the term annual percentage rate or APR, for an open end product. I know closed end you must state the whole term. Am I misreading?

From the OSC to 226.16

2. Expressing the annual percentage rate in abbreviated form. Whenever the annual percentage rate is used in an advertisement for open-end credit, it may be expressed using a readily understandable abbreviation such as "APR."

From the OSC to 226.24

. . . Unlike the transactional disclosure of an annual percentage rate under §226.18(e), the advertised annual percentage rate need not include a descriptive explanation of the term and may be expressed using the abbreviation APR. . . . .

Examiners make mistakes. They evidently confused APR and APY. Hopefully the ROE is not final and you can ask them for a cite. This should have been done before or at the exit review.