New scenario for us - came across a closed-end TX Home Equity loan that closed with an APR outside of the .125% tolerance for a regular transaction. The Final TIL signed at closing is accurate and contained no errors. They just did not wait the 3 days after re-disclosure to close. Everything I am reading in Reg. Z discusses how to cure an error in the APR disclosure and reimbursing the difference between the actual disclosure and what you should have disclosed. None of that seems to apply here. Is this just a violation without a cure? What should be done in this instance? Opinions appreciated.

Both of these statements can't be true.

Meant only that the early disclosure was inaccurate due to revisions that caused the APR to increase more than .125% and a corrected disclosure was delivered with the revised APR but the waiting period to close was ignored. Not sure how to proceed.

Reimbursement is only a consideration if the loan closed with a significantly understated APR or FC. Until the moment the borrower becomes obligated (by signing the note) you can continue delivering updated TIL disclosures and the only one that matters (for reimbursement purposes) is the one immediately preceding consummation. I have no idea how the waiting period rules work, so someone else will have to help with that.

In my opinion it is a violation you can do nothing about at this point other than use this as an example in staff training.

I was not seeing this scenario as fitting the requirements for redisclosure or reimbursements at this time either. But I had not run into this before. Appreciate both of your input. :))