CBC I: Using the FFIEC Loan APR Calculator Effectively and Reviewing Closed End Loan Advertising

Date:

Feb 16, 2022

Location:
Indiana Wesleyan University - Fort Wayne Education and Conference Center
8211 W Jefferson Blvd.
Fort Wayne, IN 46804

The first subject will be finance charges and the FFIEC Loan APR Calculator. First, we will discuss the calculation of prepaid finance charge (PPFC), as any PPFC error creates APR errors and potential restitution. While we will discuss the finance charge text from Regulation Z, our primary focus will be on the more recent consumer and mortgage loan fees that Regulation Z does not directly address, to determine whether they may be PPFC. We will then apply that knowledge and discuss numerous examples of all the different possible loan types that the FFIEC software can handle, examining loans that are correct and loans where restitution may be required. Attendees are encouraged to have a device available that will allow access to the FFIEC program. By doing so, the attendees can input the keystrokes that will be shown to get that hands-on understanding of how the software actually works.

The second portion of the day will be reviewing closed end loan advertising. We will briefly examine the regulatory text. Then we will discuss the requirements of a closed end loan compliance advertising review. This will be followed by a review of the advertising text for various closed end products, and attendees will be given the hands on opportunity to review the advertisements prior to our discussion. An advertising checklist will be provided as part of this portion of the presentation. The focus will be on the role of the compliance officer in reviewing the advertisement, and to offer concrete suggestions to avoid just saying no to the efforts of  the marketing department. While marketing personnel are welcome, the focus is not on marketing, but compliance.

Unlike our standard CBC presentation, this session will be focused on hands on activities rather than simply a review of the regulation.