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