Reg Z is not my strong point, so I apologize if the question is simple. I have already read the reg and looked in threads to see if I could find an answer. But still not comfortable with my thoughts.

We have an unsecured consumer loan and the customer receives the TILA disclosure and agreement with application (online loan application). I have no problem with this process. However, later, the customer changed the loan amount. The APR did not change, but the finance charge did because it's tied to the loan amount. The loan amount changed was lowered, so the finance charge went down as well. Did we have to redisclose the TILA prior to consumation? The finance charge changed by more than $10, but only because the loan amount changed.

I think that because the APR didn't change, then we are ok.

If it's an closed-end unsecured consumer loan, there are no early TIL disclosures that need to be provided, right?

Just provide the TIL at closing, and make sure it's accurate then.

How can you deliver a loan contract and disclosure with the application? If you do, how can the loan amount change, how does the customer sign the loan contract, etc.?

To your actual question, your TIL is not based on the legal contract. You have a number of violations.

That's correct, there are no early TIL disclosures. And yes, it is a closed-end unsecured consumer loan. Customer applies online and gets pre-approved subject to verification of critical information (eg. bank account, identity). All disclosures are given at that time, and clearly explain the process. The process is not new; many banks do it this way. Funding of the loan is really quick.

In the case I am talking about, in the process of getting verification, the customer decided to change the loan amount. So even though early TIL is not required, the loan amount changed prior to funding and the original TIL was not correct. But like I said, the APR did not change. Should have a new TILA been issued? All amounts were lower, so nothing that affected the customer.

Yes, a new TILA should have been delivered.

1026.17(c)(1) The disclosures shall reflect the terms of the legal obligation between the parties.

Thank you