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  • #2546
    frisbie
    Participant

    This is the language under variable rate features on our Home Equity disclosure regarding to how we determine the annual percentage rate.

    “To determine the annual percentage rate that will apply to your line of credit, we add a margin to the value of the index and then round to the nearest .125 percent.”

    Note: On our Home Equity Disclousre in the Historical Example box it shows a margin column but it is 0.00.

    My question is:
    Our Promissory Note does not reflect that a margin is being used to determine the annual percentage rate under the variable rate features paragraph. Do we need to some how change the language of one of these disclosures to get them to match and if so which one do we need to make the changes to?

    #3004
    JGo9
    Participant

    Frisbie,

    Your disclosures should be matching or agreeing with each other. Sounds like you need to do a bit of digging to find out what the Bank is actually doing and then make sure that your disclosures reflect the Bank’s practices accordingly.

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