Spring is the perfect time to refresh and reorganize—not just your home, but your loan portfolio as well. Whether you're originating, buying, or servicing consumer loans, ensuring your portfolio is compliant requires thorough calculation checks. Just as clutter accumulates unnoticed in your home, financial calculation errors can quietly accumulate in your loan portfolio, leading to compliance risks and financial inaccuracies.
Accurate calculations in consumer lending are essential. Errors can lead to regulatory scrutiny, financial loss, and reputational damage. Many systems today still rely on basic checks, typically using a simple "rate compare" method—comparing a loan’s stated interest rate or TILA APR against state maximums. Although straightforward, this method often misses complex nuances inherent in modern loan transactions.
Historically, loan structures were standardized, making periodic interest calculations and uniform repayment schedules common. A simple rate check was usually sufficient. Today, loan structures have evolved significantly. Loans often include daily interest accrual, extended repayment periods, various types of fees, and varied schedules for first payments—each adding layers of complexity.
Most state regulations don't simply cap interest rates or APRs. Rather, regulations usually define the maximum charge allowable, considering both the stated rate and how the interest is computed and applied. As loans increasingly incorporate varied and complex terms, the potential for regulatory noncompliance grows significantly.
At Carleton, we specialize in performing comprehensive checks beyond basic rate comparisons. We analyze complex loan structures (e.g. melded rates, stepped rates, add-on rate conversions) and verify compliance based on total charges, ensuring your loans fully align with state regulations.