How do I figure out how much Reg Z restitution is needed for an APR / Finance Charge error? It is a TRID loan too. HELP!!

Question:

We messed up an APR beyond Reg Z tolerance (on a TRID loan to boot – eek!) and know we need to give the borrower restitution. But how do we figure out the right amount to give?!

Answer:

Good for you in recognizing that restitution is needed. Many banks never get this far. To figure this out, you need to understand the Agencies Joint Statement of Policy – from 1998! It outlines the restitution provisions that apply, giving you the framework you need to know. Then, you need to understand how to use the FFIEC’s APR Tool, which will be your best friend for getting the job done. It is a fantastic, reliable, (and official) tool that will guide you through the entire process and produce a final report telling you exactly what amount is needed.
It can be a bit intimidating and confusing to understand how to use the APR tool on a TRID loan. Do not despair! Rebekah Leonard is going to walk step by step through the process in her upcoming webinar: “APY and APR Accuracy (Bonus! Using the FFIEC Calculator on TRID Loans)” on May 23, 2024.
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Learn more about Rebekah Leonard’s
APY and APR Accuracy (Bonus! Using the FFIEC Calculator on TRID Loans) webinar.