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What is the corrective action period for APR violations?
Closed end credit transactions will be subject to an adjustment if the violation resulted from a clear pattern of practice or gross negligence and is identified during the current examination.
Loans containing the violation which were consummated since the date of the preceding examination are subject to adjustment.
Open end credit transactions will be subject to an adjustment if the violation occurred within two years of the current exam.
Reference: https://www.fdic.gov/regulations/laws/rules/5000-300.html