NCLC Comments on the Importance of the APR and CFPB's Proposed TILA RESPA Integrated Disclosures (TRID)
The Bureau’s proposal almost completely abandons the Annual Percentage Rate disclosure. Rather than emphasizing the APR or proposing a substitute, the new forms emphasize the initial interest rate and monthly payment−information that can easily be manipulated by disreputable creditors and that does not accurately disclose the cost of credit. In doing so the CFPB is,…