When responding to a consumer's inquiry regarding closed end credit, must we state it as an APR? An SVP here at the bank wants to quote an interest rate range instead. So, if someone applies for a car loan, we might say, "You're rate would be between 8.00% and 8.25%." I disagree. From what I've read, if the APR cannot be determined in advance, we give an APR based on a sample transaction. He is trying to get away from quoting APR's - can't do it is my thought. As it pertains to open-end credit, same applies, right? If we're going to quote a rate, we must quote an APR. Is there any situation wherein quoting a range to a consumer would be okay? Thank you!

In reviewing Section 226.26 Oral Disclosures of APR's, I did not see any mention of quoting a range. The quoted APR can be based on a sample transaction, as you have mentioned above. The SVP may quote the interest rate, but not without quoting the APR.

And not without specifically SAYING APR or annual percentage rate. We used to cite banks for that all the time in New England.

This issue has again resurfaced. My lender says that the big banks quote a range of rates when consumers call to inquire. He wants to quote a range to encourage the customer to apply to see what they would actually qualify for based on underwriting, FICO, Auto Debit, etc. How do other banks handle this? The goal is for our lenders to have a 1-page rate sheet with only ranges of rates. Can the lender state that the Annual Percentage Rate will be between 8:00 and 8.25% based upon the consumer's individual financial condition? The lender does not want to give a sample transaction. Thank you!

As long as you're quoting APRs, not interest rates, I see nothing wrong with quoting a range. That's actually more helpful than any other way of doing it. You do not have to disclose a representative payment schedule unless you mention a trigger term. Since you're not likely to mention representative payment amounts or components of the Finance Charge, the only trigger term that presents a serious challenge is the number of payments or term ("we offer 30-year mortgages", for example.)