I have a situation where there are several(4) PTIL's in a file with different APR's. I am auditing for Reg Z redisclosure compliance to make sure we didn't need to redisclose and wait prior to closing. I have been comparing the last PTIL given to the customer and the final TIL given at closing, but an investor we sell to is telling my loan officer they don't have to compare the latest two TIL's, but they may compare APR's of any of the previous PTIL's with the final TIL and if at least 1 is within tolerance we are compliant. I need a third party opinion or reference to which method is correct.

It's my understanding that you have to compare the final TIL to the last early TIL given to the customer.