The bank received a RE application on the Internet at which time the customer received the early disclosures. The appraisal was received at which time the loan amount was increased from the original application. The interest rate was not locked until after the loan amount changed. The interest rate was locked on June 1 and the loan closed on June 3. A new GFE was prepared on June 1 with a GFE Changed Circumstance disclosure prepared. I am concerned that we did not wait for the 3/7 days because of the APR changes. Are we out of compliance?

Did the APR change more than 1/8th from what you disclosed on the original GFE? If so, then if you'd hand delivered it on the 1st, the earliest you should have closed was the 4th.

If the APR was not out of the tolerance rate, you'd be ok because you don't have to give a new TIL just because you had to redisclose the GFE at time of rate lock.

The APR changed by nearly 1/2% due to the amount of the loan being changed by $5,000 and the term changed from 15 years to 10 years. This was found in an audit so my workpapers will state that this was found as an exception. I don't know if we need to do anything at this point.