The problem with the the TIL and the APR is when it is actually seen by the borrower.  Its way to late to be seeing it at the closing or getting it in the mail a week before the closing.  I have no trouble explaining how the Bank came up with the figures, but I can't comment on the propriety of the figures.

   Our local paper prints the local bank and broker rates weekly.  It would be much more helpful to the consumer who wants to be informed, if the APR's were also displayed.  Thats when the APR, as a way to compare similar looking loan terms, would be most effective.   Perhaps consumers would then look at the Good Faith Estimate with a bit more skepticism and really question doc prep fees, application fees, etc.