In other words, your LE needs to have the correct numbers. The numbers on the CIC form (internal document) may be wrong, but have nothing to do with tolerances (other than documenting the reason for the change on the LE).
To answer your question:
Would you agree that we have a CIC form error but we don't have a tolerance issue since we have a valid CIC event?
You might have an internal policy violation, but this isn't a Reg Z violation. I agree that you don't have a tolerance error just because the CIC (internal) form was completed incorrectly.
Adam Witmer, CRCM
All statements are my opinion, not those of my employer, and should not be taken as legal advice.www.compliancecohort.com