My FI had an under-stated FC by more than $100; but the APR was within tolerance. I ran the numbers in the FFIEC APR tool, and the result shows $0.00 for Restitution. Does my FI need to reimburse the Borrower the under-stated FC amount even when the APR is not out of tolerance? I am not sureif these are two separate issues regarding reimbursement, or if it is only required when the APR is out of tolerance too.

Thank you.
(We identified why the FC was under-stated and made changes to some procedures as well as training and LOS practices); just need to confirm how to 'make it right' with our Borrower.

Restitution under the regulator's guidance for thresholds that trigger mandatory restitution orders and the thresholds to limit civil liability to the consumers are two different things.

Thank you, Randy.

The interagency enforcement policy establishes a "cross tolerance" that neither exists in Reg. Z nor Section 130 of TILA. All of the regulators calculation tools were designed to apply that additional tolerance--but only for the purpose of calculating amounts the regulators will make you reimburse. If you're defending a lawsuit or are trying to eliminate civil liability, Section 130 requires you to reimburse any understatement. If you're dealing with an investor, you might be held to the Section 130 standard, or the more generous Reg. Z standard. If you're dealing with your regulator, the Policy Statement will apply.