Before paying any attention to TILA disclosures, you must reconcile the contract with your business practice. If the contract calls for an actual/360 accrual basis and you are not abiding by this requirement, then you need to either a) change your accrual method to match the contract, or b) amend the contract so it matches your accrual method. Since your intention was to use the more consumer-friendly actual/365 accrual basis, then you will probably choose to inform affected borrowers that you are unilaterally amending the note to memorialize what you have already been doing. Until you modify the note, your TIL disclosures are wrong if they do not reflect the less favorable accrual basis because that is the legal obligation between the parties.
Before announcing the contractual change, determine whether the contracted repayment schedule causes the loan to pay to $0.00 when interest is calculated using the amended basis. If the schedule is no longer accurate, it too must be modified. Assuming the basis change is in the borrower's favor, the payment change should also be in the borrower's favor.
After you have verified or revised the payment schedule required by the contract, then you can proceed with APR and FC testing.
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...gone fishing.