President's Advisory Council on Financial Literacy

The President's Advisory Council on Financial Literacy (PACFL), it is a name that should imbue confidence of high professionalism and truthfulness. Unfortunately, I have not been unsuccessful, on 5 "Comment" occasions, of receiving any approbation that the Truth in Lending Act (TILA) of 1968 uses an antiquated method of calculating the Annual Percentage Rate, which is currently mathematically-untrue. That method is called any of the following: simple-interest, actuarial, U S Rule, or NONIMAL APR (NAPR), the interest rate for a payment period multiplied by the number of payment periods in a year. When TILA was being considered in 1967 there were no ubiquitous machines that could calculate the mathematically-true, compounded ("^") EFFECTIVE APR (EAPR). In Consumer's Reports' "Viewpoint" in February the editor wrote on a high interest loan, the borrower taking-out a loan of $400 for 16 days with $120 of interest. The current NAPR is 684% (120/400)*(365/16). The mathematically-true APR is 39,650% (((1+(120/400))^(365/16))-1). TILA allows a tolerance in stating the NAPR of 1/8th percent (0.125%). The EAPR is 311,728 of those 1/8% from the NAPR ((39,650%-684%)/0/125%). The Truth in Savings uses the EAPR, so should TILA. It is a simple as changing the words in TILA for "multiplied by" to "compounded for". PACFL should recommend the change to the President and Treasury.

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