The 30-day correction period under 1026.19(f)(2)(iii) applies when there is a post-consummation event that causes the disclosures to become inaccurate, resulting in a change to an amount actually paid by the consumer.
The 60-day correction period under 1026.19(f)(2)(iv) only involves changes due to non-numeric clerical errors.
The 60-day correction period under 1026.19(f)(2)(v) only relates to tolerance overcharges identified after closing that weren't resolved in the CD issued at or before the closing.
It appears your situation does not fit either of the last two criteria, so that leaves the 30-day provision in 1026.19(f)(2)(iii). But there's no post-closing event here. What you have is an disclosure violation error that doesn't appear to be curable. You can, however, send a corrected CD with a letter of explanation. Since the mistake didn't affect amounts paid by the customer, and there appears to be no consumer harm, I'd consider it an isolated incident.
Did the error in those numbers get carried over to the escrow section on page 4 of the CD?
_________________________
John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8