Skip to content

Program to Run Against Loans to Validate APRs

Question: 
Does anyone know of a technology program that can be run nightly against all loans made that will validate the APRs?
Answer: 

From the control perspective, this is a good idea. As a practical matter, however, it's next to impossible. Many reimbursable APR understatements are caused by misclassification of fees that should be treated as PFCs, but are not. Software can't classify a fee. Another recurring type of APR/FC problem begins with incorrect index values and payment schedules for discounted or premium ARMs. Software that can recalculate ARM payment schedules and then verify the downstream TIL disclosures will be very complex (expensive.)

First published on 05/26/2014

Filed under: 
Filed under compliance as: 
Filed under lending as: 

Search Topics