APR and APOR 2022 | ProBank Austin | 26 May 2022 | Webinar

The concept of the Annual Percentage Rate is fundamental to the Truth-in-Lending Act (as implemented by Regulation Z). Normally, we worry about the disclosure of APR, as it is a “material” disclosure and would be a significant violation, with potential restitution, if disclosed incorrectly. However, APR is also important in that it is used in order to determine whether a transaction is subject to or has specific treatment under certain rules. Specifically, certain rules compare the APR for a transaction with the “average prime offer rate” (APOR) which is calculated based on survey data for a hypothetical, “best quality,” 80% loan-to-value, first lien loan, and use such averaged rates. What are these rules and what are the results of this comparison?

This webinar will go into detail the comparison of APR and APOR, including the importance of rate-set date, whether a transaction is fixed or adjustable, open-end or closed-end, and the term. We’ll discuss two rules that provide for a different calculation of APR. We will review the rules that use this comparison, when a different calculation of APR may be required, and the importance of checking throughout the application process.

Here Is What You Will Learn:
• Rules that require APR/APOR comparison
• TILA/Regulation Z – High Cost (*different calculation of APR)
• TILA/Regulation Z – HPML
• TILA/Regulation Z – QM – Safe Harbor
• TILA/Regulation Z – QM – General QM Option (*different calculation of APR)
• TILA/Regulation Z – High Cost/QM – Points and Fees
• HMDA
• How to determine APR
• How to determine APOR - the importance of:
• When the institution sets the rate
• Term of the transaction or initial period
• Fixed versus variable
​​​​​​​• Clarification for Construction-Permanent Loans

Format/Instructional Method: Group Internet Based.
An online presentation and any additional supplemental materials, as applicable, will serve as the basis of the presentation. You will have the option to stream the audio through your computer or dial-in using a telephone number/PIN. Ample time will be dedicated to taking questions from attendees. Be sure to submit your questions during the webinar, as we are unable to offer telephone or email support after the presentation.

Who Should Attend:
This webinar will be of value to anyone involved in mortgage lending compliance, including lending officers, compliance officers, loan administration, loan review and internal audit personnel.

2022 Speaker

PRESENTER:

Anetria Cohen
Vice President, ProBank Austin