Does the tangible net benefit rule require creditors to determine a payment for the principal loan amount only, and then add the 3-year fee amortization amount?
• The new rule requires that the “monthly payment” figure for purpose of the tangible net benefit form contain an amount reflecting recoupment of costs and fees during the first 3 years of the loan. This may result in a small portion of double-counting, since a portion of the underlying payments will also represent recoupment of those fees, but over the full term of the loan.
Related Questions
- Does the tangible net benefit rule require creditors to determine a payment for the principal loan amount only, and then add the 3-year fee amortization amount?
- Does the Tangible Net Benefit rule apply only to loan applications received after the effective date of the Act and rule (January 1, 2008)?
- What loans are now subject to the tangible net benefit test set forth in the Bureaus’ tangible net benefit rule?
