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A lender quotes an APR of 4.25% on a mortgage loan, but the actual APR calculation results in 4.28%. Under TILA's APR accuracy tolerance, is this disclosure compliant?

Correct Answer

A) Yes, because the difference is less than 0.125 percentage points

Under TILA/Regulation Z Section 1026.22, for closed-end credit secured by real property, the APR is considered accurate if it is not more than 0.125 percentage points above or below the actual APR. Since 4.28% - 4.25% = 0.03%, which is less than 0.125%, this disclosure is compliant.

Answer Options
A
Yes, because the difference is less than 0.125 percentage points
B
No, because any difference makes the disclosure inaccurate
C
Yes, because the difference is less than 0.25 percentage points
D
No, because the quoted APR is lower than the actual APR

Why This Is the Correct Answer

Under TILA/Regulation Z Section 1026.22, for closed-end credit secured by real property, the APR is considered accurate if it is not more than 0.125 percentage points above or below the actual APR. Since 4.28% - 4.25% = 0.03%, which is less than 0.125%, this disclosure is compliant.

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