I am looking at a situation involving a mutliple advance loan with interest only payments, and the principal and interest being due at maturity.

When I use the Construction Loan feature to see what the effect would be of an improperly disclosed finance charge, APR Win is not spelling out any restitition.

The APR difference is enough for restitution, and the Finance Charge difference is enough for restitution, but I'm just getting a disclosure sheet with no restitution information.

Am I missing something?

I've used APR WIN to calculate these, and it's always worked. I just tried one with really outrageous numbers, and noticed a box with a tolerance choice - have you tried checking the other box?

That's my best advice unless you want me to try the calc through my APR WIN.

That's what is so weird - No tolerance box comes up, no questions of tolerance, no questions on restitution, nothing!

Perhaps I downloaded a defective copy?

Could be! That software is a little cantankerous anyway! If you want to send me a private email with the particulars, I'll be happy to run it through mine and fax you the report.

For what it's worth, these loans are "irregular" transactions because they have multiple advances. The APR tolerance increases to .25% for "irregular" transactions.

On the FC side, you get the Rodash tolerance of $100 because the loan is secured by real property or a dwelling.

When applied in the reimbursement context, you can "cross-apply" the tolerances--in other words, you get the APR equivalent of $100 and the FC equivalent of .25%. These "cross-applied" tolerances are in additon to the Reg. Z disclosure tolerances.

Thank you Richard, however the APR and Finance Charge were both well beyond even those tolerances.