We disclose our construction mortgages as one transaction(temporary/permanent). We charge interest only on the amount outstanding during the construction period. We prepare and give the disclosure within 3 days of the application and base it on the anticipated construction period as shown in the Appendix to Reg Z. We put e's (estimate) beside the APR, Finance Charge and Total of Payments. Recently we have had several constructions take longer to complete than what was originally anticipated. We did not re-disclose to the borrower as the APR was not affected by the extended construction period. Our Audit Department reviewed a couple of these files recently and recommend we should re-disclose because the Finace Charge, Total of Payments and Payment Schedule disclosed is incorrect. We have never re-disclosed previously under this circumstance. Would appreciate anyones help to assure me that re-disclosure is not necessary.

I don't think you need to redisclose. This is based on the following commentary in Reg Z, Section 226.17(c):

17(c) Basis of disclosures and use of estimates.

Paragraph 17(c)(1).

1. Legal obligation. The disclosures shall reflect the credit terms to which the parties are legally bound as of the outset of the transaction. In the case of disclosures required under §226.20(c), the disclosures shall reflect the credit terms to which the parties are legally bound when the disclosures are provided. The legal obligation is determined by applicable state law or other law. (Certain transactions are specifically addressed in this commentary. See, for example, the discussion of buydown transactions elsewhere in the commentary to §226.17(c).)