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T. I. L. A. REGULATOR -- TOLD YOU SO
In the continuing series of videos pertaining to the "Truth In Lending Act" (T.I.L.A.) we reached the point where an alleged "Regulator" responded to the Complainant.
Specifically, the Missouri Division of Finance (DOF) which claims to regulate banks, credit unions, and lenders operating in Missouri. This Regulator informed the Complainant that it had contacted the Lender and gave the Lender 21 days to reply.
Instead of waiting 3 weeks I asked the Complainant to ask the Regulator to "Do the Math" and verify the Complainant's calculations.
Instead of following the law on calculating APR the Regulator relied on a computer program (calculation tool) from a website, and replied to the Complainant that the program calculated APR was within tolerance allowed by law.
https://www.ffiec.gov/examtools/FFIEC-Calculators/APR/#/accountdata
What the Regulator failed to mention is that the "Law" specified how APR is to be calculated "The annual percentage rate shall be determined in accordance with either the actuarial method or the United States Rule method. Explanations, equations and instructions for determining the annual percentage rate in accordance with the actuarial method are set forth in appendix J to this part" (12 C.F.R. § 1026.22 Determination of annual percentage rate).
This is not what the Regulator did. (Neither have we, but the method I show was provided by AI (GROK), and is close enough for government work.
But there is more.
Neither the Missouri Division of Finance (DOF) nor any other State Regulator is mentioned in T.I.L.A., which specifically mentions that Federal Regulators are responsible for T.I.L.A.
Nevertheless, "IS" is what it is, and so what to do now is the basis of the video.
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