The truth in leading law simply states that all lenders have to give an
"apr" rate for comparison purposes for the actual number of days in a
year. The truth in leading law doesn't explain the math behind the
calculations nor the laws and common practices on how to perform the
calculations. Taking the arp rate and dividing by 365 no way gives the
daily interest rate. If that was the case then

I/365 = ((1 + I/365)**365) - 1

I have never seen any US banks give me a different interest rate for
months that are different number of days nor loans that have different
payments for diffferent length months. The monthly interest rates are
all the same because of the 5 bank holidays.


--
joel
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