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One of our customers signed loan disclosures for a car loan, but the loan will not be funded until more than a week after we disclosed the loan’s APR. Because the disclosures were based on a disbursement date that has already passed, the APR calculation will be changed (as the loan period has changed by a week). Do we need to do new loan disclosures? – IBA Compliance Connection

IBA Compliance Connection

Your go to source for compliance!

One of our customers signed loan disclosures for a car loan, but the loan will not be funded until more than a week after we disclosed the loan’s APR. Because the disclosures were based on a disbursement date that has already passed, the APR calculation will be changed (as the loan period has changed by a week). Do we need to do new loan disclosures?

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Whether you need to redisclose depends on how much the disclosed annual percentage rate (APR) differs from the APR based on a slightly shorter loan period. Regulation Z requires you to redisclose all changed terms if the disclosed APR differs from the actual APR by more than 1/8 of 1 percent. 12 CFR 1026.22(f)(2).