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Does TIL 1026.26 requirement to respond to oral rate inquiries to always include APR (or sample APR) apply to all TIL applicable loans?
It’s in the Misc section between Closed-End and MTG, however I do not see anything to indicate it is only to be applied in certain circumstances.I believe you are asking if it would apply to open-end loans because of where it is housed. There is specific information in 1026.26(a) pertaining to open-end credit:
(a) Open-end credit. In an oral response to a consumer’s inquiry about the cost of open-end credit, only the annual percentage rate or rates shall be stated, except that the periodic rate or rates also may be stated. If the annual percentage rate cannot be determined in advance because there are finance charges other than a periodic rate, the corresponding annual percentage rate shall be stated, and other cost information may be given.
Official Interpretation
26(a) Open-End Credit
1. Information that may be given. The creditor may state periodic rates in addition to the required annual percentage rate, but it need not do so. If the annual percentage rate is unknown because transaction charges, loan fees, or similar finance charges may be imposed, the creditor must give the corresponding annual percentage rate (that is, the periodic rate multiplied by the number of periods in a year, as described in §§1026.6(a)(1)(ii) and (b)(4)(i)(A) and 1026.7(a)(4) and (b)(4)). In such cases, the creditor may, but need not, also give the consumer information about other finance charges and other charges.There is also information on closed-end credit.
Does the requirement to provide oral APR in response to inquiry about rates also apply to non-dwelling secured loans applicable to TIL? For example auto-loans?
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