If a 0-tolerance fee is included and disclosed on customer's LE but we later determine that was our bank error and we will NOT be collecting or charging the customer that fee at closing,

-- Ii know we cannot re-disclose the LE because there is no valid change of circumstance but my understanding is that we would be OK to simply "leave that fee off" of the initial CD and this would not create a tolerance issue because the fee is not being collected, or charged, AND separately, would not be a violation under the APR disclosure because APR tolerances are measured from CD to CD correct?

Just want to confirm "no issue" with removing a (0-bucket) fee as long as we will "NOT" charge it and as long as it's left off the "initial" CD?

Well, you would be required to remove on the next disclosure issued regardless if it was the initial CD or a revised LE to meet the good faith standards. Disclosing a fee and then not charging it would never create a tolerance violation.

Ok, thank you for confirming NO tolerance violation for not charging a fee

Can you also confirm in a case where the "next" disclosure is an initial CD, the APR change would also never lead to a violation in APR tolerance since the TRID Rule only sets an APR tolerance between CD's "not" between LE to CD?

APRs are only tested during the CD disclosure phase.

One more general question: Is there any reason a lender should (Not) to send a corrected closing disclosure if we find an error but determine we are already outside of the (30) or (60) day window to send the corrected disclosure? My understanding is that we may not be able to cure the violation at that point but nothing prohibits us from sending the correct disclosure out even if it doesn't cure a violation?

I am of the mind that sending the consumer a corrected disclose shows a good faith effort regardless of whether it actually cures the violation, especially if it involves a situation where you owe them money. If it is a clerical error, then that would most likely be done on a case by case basis depending on what it involved and how long it had been.

thank you sir !