Thought Leadership
U.S. Rule vs Actuarial Method APR Disclosure
Posted on September 17, 2012
U.S. Rule vs Actuarial Method APR Disclosure While the subject has been around now for over 30 years, it's still a question we get asked a lot: should I use the actuarial or U.S. Rule method to compu...It's All in the Payment - Part II
Posted on August 27, 2012
It's All in the Payment - Part II We've been away for a while without a new blog post waiting for the launch of the new Carleton, Inc. website which will be the new home of the Carleton Complian...Do your lending calculations handle leap year?
Posted on February 29, 2012
It’s Leap Day – Do your lending calculations handle leap year? It’s leap day, February 29th. While leap day, and leap year, is ostensibly a corrective calendar measure, a...Why One Size Doesn't Fit All
Posted on November 28, 2011
Why One Size Doesn't Fit All Fighting the conception/perception that the credit industry is operated and regulated on a standardized basis and that parameters are of the “one size fits all&rdqu...The Rule of 78ths
Posted on October 20, 2011
The Rule of 78ths What's in a name? Often through this blog, and other writings over the years, you have heard me preach clear communication. The use, and mis-use, of labels, slang, jargo...Navigating the Pendulum Swing
Posted on September 21, 2011
Navigating the Pendulum Swing What do the following have in common? HMDA, Fair Lending, Suitability, Arbitration, CRA, Ability to Repay, Interchange Fees, Credit Freeze, Risk Retention, Appraise...The Match Game
Posted on August 26, 2011
The Match Game An interesting discussion I have often with members from both the industry and the regulators is the proper way to decide if a computed number is "right". Generally, we see two school...A Fee by Any Other Name....
Posted on August 12, 2011
A Fee by Any Other Name.... A particularly key compliance component of our project definition process for new clients is the analysis of the properties associated with any fees pa...The Deception of Dates
Posted on July 28, 2011
The Deception of Dates There are days when I absolutely hate the month of February. And not just during that month with its sub-zero temps, dark days and endless snow, but when the fact that it...Every Fee "Affects" the APR
Posted on July 13, 2011
Every Fee "Affects" the APR When gathering information to define software, one of the critical areas for accurate disclosure is determining the nature of any fees that will be charged by the l...