ASPIRE APR Functionality FAQ
ASPIRE APR Functionality FAQ
What are the APR
Regulations?
Beginning December 9, 2022, under the California Code of
Regulations Title 10, Chapter 3, commercial lenders are required to provide an APR,
along with other values on a regulated disclosure document for all financing
offers. For more details on requirements, reference the Department of Financial
Protection and Innovation press release dated June 14, 2022 (https://dfpi.ca.gov/2022/06/14/dfpis-commercial-financing-disclosure-regulations-approved-to-become-effective-as-of-december-9-2022/).
Similar disclosure requirements
have been proposed for New York, though they have not been finalized to
date. For additional information The
New York State Senate Bill S5470B (https://www.nysenate.gov/legislation/bills/2019/S5470) can be reviewed for requirements and current legislative status.
Similarly, the UK has had an APR regulation in place for
regulated deals since 2007. Additional information and requirements can be found in the Financial Conduct
Authority Handbook (https://www.handbook.fca.org.uk/handbook/MCOB/10/?view=chapter).
What version of
ASPIRE are the requirements of these regulations met?
UK: Beginning in ASPIRE version 5.16, LTi implemented an APR in accordance with the specifications previously noted.
US: Beginning in ASPIRE version 5.20.43, LTi implemented an APR coded to the US specifications as well as additional document tags to support the required additional values for the disclosure document.
Which customers are
affected by these regulations?
Any customer doing business in California, New York, and/or the UK will be affected by these regulations, respectively.
What has been added
to ASPIRE to support the APR requirements?
The following items have been added to ASPIRE to support the APR requirements:
- A Global Setting to control which variation of the calculation is used; US versus UK calculation.
- The ability to calculate and trigger the re-calculation of the APR prior to booking as well as post booking (should this need arise).
- The ability to view the calculated APR from Contract Explorer - Main screen - Payment Schedule tab.
- The ability to use the APR on documents.
- The ability to configure and generate the prescribed US disclosure document in accordance with the regulations previously noted.
- The ability to set the APR using the ASPIRE API.
How can customers
generate the required document for only the required contracts?
Data
views have been added for contract-level document templates that include the
required document tags needed for APR disclosure notifications to be generated
out of ASPIRE. These can be found by utilizing the Contract APR and Contract
APR Payment Description data views that are available beginning in 5.20.43. Users
can leverage all existing document generation functionality with this
information included on disclosure notices as of the 5.20.43 release.
Are there additional features planned for APR disclosure functionality?
At this time, all work necessary to meet requirements for the previously referenced regulations have been completed as
of the 5.20.43 release of ASPIRE.
Where can I find additional information about this functionality?
In addition to the 5.20.43 release notes and ASPIRE Help a user guide for this functionality can be viewed in Sharepoint using the link below.
User Guide: APR_Calculations_In_ASPIRE.pdf
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