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Is there any difference in the fees that must be included in Regulation Z’s APR calculation for in-house loans? – IBA Compliance Connection

IBA Compliance Connection

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Is there any difference in the fees that must be included in Regulation Z’s APR calculation for in-house loans?

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No, there is no difference in the fees that you include in calculating the APR for in-house loans. Neither Regulation Z nor its appendices (which explain how to calculate a loan’s APR) distinguish between in-house and outside loans.

For resources related to our guidance, please see:

  • Regulation Z, 12 CFR 1026.14(a) (“The annual percentage rate is a measure of the cost of credit, expressed as a yearly rate.”)
  • Regulation Z, Appendix J – Annual Percentage Rate Computations for Closed-End Credit Transactions
  • Regulation Z, Appendix F – Optional Annual Percentage Rate Computations for Creditors Offering Open-End Credit Plans Secured by a Consumer's Dwelling