A customer is overcharged on a loan fee ($195.00, should have been 4% of loan amt) resulting in an APR >40%...Can a straight refund be done, or should we redisclose? This is an unsecured consumer loan. Where would this situation be addressed in the regs?

If you are off by more than a 1/8th from your initial TIL, you would re-disclose.

If this loan is closed, you can't redisclose.

Thanks for your help guys. We're refunding and will have good documentation placed in credit file.