During a recent file review we found that the APR on the early TIL for a closed-end mortgage loan was understated by .80% compared to the final TIL (this was in large part due to a $5,000 origination fee that was not disclosed on the early GFE/TIL).

It's been a couple years since this loan closed and I'm seeking clarification on what steps we need to take to rectify the situation.

None. Since it was on an early disclosure and I assume the final was correct, it is a violation that cannot be corrected.

Since the eTIL is an estimate....how is that an uncorrectable "violation"? I don't really see it as a violation, more so than an error. I'd be more bothered by the GFE being off by such a large amount.

Just curious, not arguing!

Uncorrectable from the purposes of a timeline - 3 days from app.

Most ROEs I have seen indicate that failing to properly estimate is cited as a violation as the bank could not defend that the estimate was made in good faith. Of course for this to make it to an ROE there most likely would have to be a pattern or practice. If the $5,000 fee was known about and missed at the time of providing the estimate, I would classify it as a violation.

I would however, as you stated, be just as concerned regarding possible UDAPs.