I get so lost sometimes.........
A customer applied for a 1 year ARM product (4% interest rate)to purchase their primary residence, early papers were sent, APR on ETIL 4.117%. Customer changes mind and decides they want the 3 year ARM product (5.00% interest rate), APR on final TIL 5.155%. Re-disclsoure of early papers was not done even though we had a legit CC as there were no changes in fees. Is this a violation of the tolerance thresholds on the APR? If so, where do I go to see what I need to do? or are we ok because the final TIL would be accurate? Help please.........

Your APR increased outside the allowable tolerance. You should have disclosed and waited 3 business days before closing if provided face to face or 6 days if mailed.

This is a violation of 1026.19(a) and you cannot cure the violation after the fact (loan closed). You need to retrain, revamp procedures, document and move on to the next opportunity.

Thanks Dan. I was afraid of that.
As they say......Live and Learn. :-)