This field map outlines required disclosure alignments for personal loan Truth in Lending (TIL) page APR and finance charge entry fields. It is designed for administrative staff coordinating closing document reviews with loan servicers and Settlement Desk teams, to reduce common errors that delay loan funding. All guidelines align with Consumer Financial Protection Bureau (CFPB) Regulation Z requirements for closed-end personal loan disclosures, and apply to both fixed and variable rate products for personal, non-commercial use. Misalignment between APR box values and finance charge totals is one of the top three causes of TIL disclosure rejection during closing review, so consistent application of these rules can cut processing timelines by an average of 2 business days per file, per internal administrative data.
Settlement Desk
APR Box Field Placement Specifications
Per Regulation Z requirements, the APR box must be placed in the upper right quadrant of the first page of the TIL disclosure, no more than 2 inches below the top edge of the page. The box must be bordered by a solid black line, with all text inside the box printed in minimum 10-point bold font, and separated from all other content on the page by at least 0.5 inches of white space on all sides. The box may only include required numerical disclosures; no promotional language, disclaimers, or optional product advertisements are permitted within or adjacent to the box. The first line of the box must be clearly labeled “Annual Percentage Rate” and include the applicable APR for the loan, rounded to the nearest 1/8 of one percent per CFPB rules. For variable rate loans, a second line must be added listing the maximum possible APR over the life of the loan, and a third line noting the frequency of rate adjustments. Illustrative example: a 60-month variable rate personal loan with a starting APR of 12.25% and a lifetime cap of 19.99% would list both values in the APR box, along with a note that rates adjust quarterly based on the prime rate index.
Finance Charge Column Mapping Guidelines
The finance charge column, located on the left half of the TIL page directly below the loan term disclosures, must list all fees and interest costs associated with obtaining the loan, aggregated into a single total at the bottom of the column. All line items in the column must map to verified source documentation, per the following field map:
| Field Name | TIL Page Location | Required Data Source | Validation Check |
|---|---|---|---|
| Nominal APR | Upper right APR Box Line 1 | Loan origination system (LOS) amortization schedule output | Match total interest paid over loan term divided by amount financed, annualized per Reg Z calculation rules |
| Total Finance Charge | Itemized finance charge column Line 7 | Sum of all interest, origination fees, credit report fees, and prepaid finance charges | Exclude optional add-on products (payment protection, GAP insurance) unless the borrower explicitly opted in to the product in writing |
| Amount Financed | APR Box Line 2 | Stated loan principal minus total prepaid finance charges | Match net disbursement amount listed in the official closing instruction document |
| Variable APR Lifetime Cap (if applicable) | APR Box Line 3 | Signed promissory note rate adjustment terms | Confirm cap does not exceed applicable state usury limits for non-secured personal loan products |
| Prepaid Finance Charge Subtotal | Finance charge column Line 3 | Closing disclosure fee summary section | Sum matches total prepaid amounts deducted from loan principal prior to disbursement to the borrower |
All line items in the finance charge column must be listed in descending order of dollar value, with clear labels that match the fee names used on the closing disclosure to avoid borrower confusion. Any fees classified as “finance charges” per Reg Z rules must be included in this column, even if they are paid to a third party (such as a credit reporting agency or title company) rather than directly to the lender. The total finance charge must be listed in bold font at the bottom of the column, with a clear note that this is the total cost of credit over the life of the loan.
Amount Financed Field Cross-Reference Rules
The amount financed is the net amount of credit the borrower has access to under the loan terms, and is not equal to the stated loan principal listed on the promissory note in most cases, due to prepaid finance charges that are deducted prior to disbursement. To ensure accuracy, complete a three-way cross-reference for this field across all loan documents: first, pull the stated loan principal from the signed promissory note, then subtract the total prepaid finance charges from the finance charge column to calculate the expected amount financed, then confirm this value matches the amount listed in the APR box, the net disbursement line on the closing disclosure, and the funding amount recorded in the LOS. Discrepancies of more than $1 between any of these values require immediate correction, as the CFPB allows zero tolerance for misstatements of the amount financed on closed-end personal loan disclosures. Illustrative example: a $15,000 stated principal loan with $675 in prepaid origination and credit check fees would have an amount financed of $14,325, which must be listed consistently across all TIL and closing disclosure fields. Optional product fees are not subtracted from the principal to calculate the amount financed, as these products are not required to obtain the loan, and the borrower may opt out of them at any time prior to closing.
TIL Page Form Consistency Verification Protocols
Before submitting a TIL page for final review, complete the following four-step verification process to ensure full consistency across all fields: First, complete a visual layout check to confirm the APR box is in the required upper right quadrant location, meets font size and spacing requirements, and does not include any unapproved text or promotional material. Second, run the numerical consistency check by comparing all values in the APR box to the corresponding line items in the finance charge column, and confirming all calculations align with the field map listed above. Third, complete a document cross-match to confirm all values on the TIL page match the corresponding values on the closing disclosure, promissory note, LOS output, and fee summary documents. Fourth, confirm the borrower signature block is located directly below the total finance charge and APR box disclosures, so borrowers are explicitly acknowledging they have reviewed these key cost disclosures prior to signing. All verification steps must be documented in the loan file audit trail, with the name and date of the administrative staff member who completed the check, for future compliance audits. Settlement Desk review teams prioritize files with completed verification trails, as they have a 75% lower rate of post-closing disclosure errors.
Discrepancy Flag Box Error Resolution Steps
If a discrepancy is identified during verification, or if the TIL page is returned with a discrepancy flag from the review team, follow these standardized resolution steps: First, isolate the discrepancy by identifying which fields do not match, and pull all source documentation for each field to determine which value is the correct, compliant value per Reg Z rules. Second, correct the erroneous field on the TIL page, and update any corresponding fields on related disclosures (closing disclosure, promissory note addenda) to ensure full consistency across all loan documents. Third, re-run the full four-step consistency verification protocol to confirm no additional discrepancies exist after the correction is made. Fourth, attach a formal correction notice to the loan file, explaining the nature of the error, the source of the correct value, and the name and date of the staff member who made and verified the correction. Fifth, if the original erroneous TIL page was already provided to the borrower, issue the updated corrected TIL page to the borrower for re-review and signature, and apply any mandatory waiting periods required under Regulation Z. Note that discrepancies that result in an APR misstatement of more than 0.125% require a new three-day waiting period before the loan can close, to give the borrower time to review the corrected disclosures.
Before submitting your next personal loan closing package for formal review, complete the three-way cross-reference between the APR box, finance charge column, and amount financed field to catch 90% of common TIL disclosure errors before they are flagged by compliance teams.
