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Recorded: May 26, 2022
Presented by: Ms. Anetria Cohen, VP and Senior Consultant, FORVIS

A two-hour webinar providing a detailed review of this comparison, the rules that use it (and why it’s used), and differences in the calculation of APR.

The concept of the Annual Percentage Rate is fundamental to the Truth-in-Lending Act (as implemented by Regulation Z). Normally, we worry about the disclosure of APR, as it is a “material” disclosure and would be a significant violation, with potential restitution, if disclosed incorrectly. However, APR is also important in that it is used in order to determine whether a transaction is subject to or has specific treatment under certain rules. Specifically, certain rules compare the APR for a transaction with the “average prime offer rate” (APOR) which is calculated based on survey data for a hypothetical, “best quality,” 80% loan-to-value, first lien loan, and use such averaged rates. What are these rules and what are the results of this comparison?

This webinar will go into detail the comparison of APR and APOR, including the importance of rate-set date, whether a transaction is fixed or adjustable, open-end or closed-end, and the term. We’ll discuss two rules that provide for a different calculation of APR. We will review the rules that use this comparison, when a different calculation of APR may be required, and the importance of checking throughout the application process.


  • Rules that require APR/APOR comparison
    • TILA/Regulation Z – High Cost (*different calculation of APR)
    • TILA/Regulation Z – HPML
    • TILA/Regulation Z – QM – Safe Harbor
    • TILA/Regulation Z – QM – General QM Option (*different calculation of APR)
    • TILA/Regulation Z – High Cost/QM – Points and Fees
    • HMDA
  • How to determine APR
  • How to determine APOR – the importance of:
    • When the institution sets the rate
    • Term of the transaction or initial period
    • Fixed versus variable
  • Clarification for Construction-Permanent Loans
Who Should Listen

This webinar will be of value to anyone involved in mortgage lending compliance, including lending officers, compliance officers, loan administration, loan review and internal audit personnel.

Program Level: Basic

Prerequisite/Advanced Preparation: Basic Knowledge of Lending Regulations

Field of Study: Specialized Knowledge

Copyright Disclaimer

Any recording, transmission, retransmission, or republishing of any portion of this webinar is prohibited.