We disclosed a 5/1 ARM with 30 year amort; the rate is locked at disclosure. Our rates are based on the US Treasury. By the time the loan actually closed the Treasury had adjusted a bit which made the finance charge increase by $144. (No fees were left off or anything like that.) The APR remained well within tolerance. Should we have provided a revised TIL 3 days prior to closing because of the finance charge $144 difference?
Dollar amount is not the determining factor for redisclosing an ETIL. If the APR did not change by more than .125%, no redisclosure was required. The final TIL given at the closing table would reflect the final numbers, including the $144.