I tried searching the forum for this but was unsuccessful (probably user error, as it seems like it would be a common/basic question... but I digress).
We have an issue where we discovered through post-closing QC that we failed to preface a title charge with, "Title -" on the Closing Disclosure.
However, since we discovered this > 60 days after consummation and it is a clerical error, we are having an internal discussion about whether a corrected CD is required, since §1026.19(f)(2)(iv) outlines that in order to cure this violation, a corrected PCCD must be issued to the borrower within 60 days.
My thought is that the corrected CD should still be issued, as minor as that error seems to be.
I feel like I've read some type of guidance before that was more along the lines of, "Within 60 days, or when the error is discovered, whichever is earlier," but I can't find that verbiage. Does anyone know if such verbiage exists related to any type of post-consummation cures?