[Sean Cash]

The term issue and any enforcement action again can be easily overcome. Anyone could provide an offer with an APR cost assuming a payoff of 12 months or whatever the average payoff of an MCA is.

You will inevitably be held to this number when the customer uses this as the basis for their comparison.

and that variations as result of payoff timing differences will adjust actual rate.

And when it varies from that number, despite your having legally disclosed "variations may occur," no one will care about that disclosure. Class actions, FTC lawsuits would undoubtedly follow.