First time poster - long time lender.
Having a case of the Monday's.

Situation: Properly documented and disclosed application to a consumer on 2/10/15 gets ready to go to the closing team Friday for a Monday package. Closer alerts me that we have a "$100.00 variance error" and we need to wait 3 days to close. I dig in and here is my data:

Original Application
Rate: 3.125%
Term: 180
APR 3.180%
Finance Charge: $81,058.08
Amount Financed: $313,292.29

Prelim Closing Docs
Rate: 3.125%
Term: 180
APR: 3.190%
Finance Charge: $81,273.49
Amount Financed: $313,076.88

My closer is telling me that since my Finance Charge is $100.00 greater than my initial disclosure I'm out of phase with the rules.

I've been on this site for 2 hours doing MDIA / TILA searches. I've found links to this article several times: https://consumercomplianceoutlook.org/2011/first-quarter/mortgage-disclosure-improvement-act/

I've read it 4 times. For the life of me I cannot get past this section: "Regulation Z also states that for loans secured by real property or a dwelling, a disclosed APR will also be deemed accurate if the error resulted from the disclosed finance charge and the disclosed finance charge is not understated by more than $100 or if it is overstated."

In reading early in the document linked above I do see, and feel strongly, that my file does NOT need any kind of redisclosure. But, I cannot read the link noted above and defend my position when faced with the understatement of $100 as, sure enough, the FC in the initial application and the FC in the final document are apart by more than $100.00

Help...please.