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In answer to the question, “… can current disclosures be strengthened and improved?” The answer is an overwhelming, “Yes!” The method of calculating the annual percentage rate (APR) used in the Truth in Lending Act (TILA) in 1968, when the act was passed, should be changed from the antiquated simple-interest, nominal APR (NAPR) to the mathematically-true, compounded [^], effective annual percentage rate (EAPR). It is as simple as changing in TILA the words “multiplied by” to “compounded for.” An extreme example of the deception of using the NAPR is a payday loan on which $100 is borrowed to be repaid in 14 days with $15 in interest. The NAPR is 391.071%, calculated as (15/100)*(365/14). The EAPR is 3,723.661%, calculated as ((1+(15/100))^(365/14))-1. TILA allows a tolerance of accuracy in expressing the APR of 1/8% (0.125%). The mathematically-true, EAPR is not merely slightly over 1 of those 0.125%s, it is 26,660 of those 0.125% over, calculated as (3,723.661%-391.071%/0.125% … ASTRONOMICALLY DECEPTIVE and Unconscionable. The Truth in Saving Act uses the EAPR and names it the Annual Percentage Yield (APY), so, why not the TILA, too?
Catholic University Program on Proposed Consumer Financial Protection Agency
Catholic University Law School is presenting what sounds like a terrific program on the proposed Consumer Financial Protection Agency on October 20, 2009 from 5:00 to 6:30 p.m. Admission will be by reservation only. Speakers include Michael Barr, Assistant Secretary of the Treasury for Financi...
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