It’s the end of an era. I have been in audit or compliance for {shudder} over 30 years now, and in all that time have had APRWin as a constant companion to test the validity of those APRs. It’s like an old friend. The current version has been around since May 2008. APYWin isn’t quite as old but I’ve been using it forever as well, almost as long as Regulation DD has been around (1993); the current version is from May 2009. Am I romanticizing them? Sure. Do they have their faults? Sure – but they came in handy.
Well, those days are over. These tried-and-true programs were supplanted on April 16, 2020. The downloadable programs were yanked away from the OCC homepages and replaced with this startling message:
The APRWIN/APYWIN program has been discontinued. Refer to OCC Bulletin 2020-40 or visit the FFIEC Federal Disclosure Computational Tools at https://www.ffiec.gov/calculators.htm.
Sure, we knew this was coming since the Regulators hinted as much at a meeting we attended earlier this year; it was still a shock.
Ok, enough waxing nostalgic. Both programs have been updated for current times. The APR Tool, as it’s now called, contains the same features as its prior software-based version, but this new tool can also calculate TRID-related changes such as the Total of Payments and TIP (Total Interest Percentage) and for non-TRID loans, incorporate a MAPR calculation as well. While we did not do extensive testing, we did encounter what seems to be a glitch in calculating construction/permanent loans. The construction interest did not appear to factor into the TIP calculated by the tool, so it did not match the TIP correctly disclosed on two loan files we tested.
The APY Tool does not appear to be any different from the current software version. In our limited testing, we did not encounter any errors.
Out with the old and in with the new. The tools are hosted on the FFIEC.gov website from a link on the left-hand side titled Computational Tools. Give them a try!
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