Good afternoon-
Curious if a guru can provide a 2nd opinion/guidance to a situation regarding an under-stated finance charge.
A loan closed last week (purchase) with the wrong PMI disclosed/calculated.

The Finance Charge is under stated to the exact amount of the actual monthly PMI charged in the amortization schedule.
The APR is not out of tolerance. Does my FI need to cure the difference and provide a correct CD post-close?

Please let me know if if there is more information I should be providing.

Thank you so much for any guidance.

The cure would be for the bank to pay for the PMI since it appears the premiums were not properly treated as a finance charge.

Hi Randy- Thank you. So, would the Bank 1) cut a check to the MI agency and 2) issue a revised CD to Borrower?
I have never experienced an under-stated finance charge due to PMI. Or is the CD technically correct and my Bank needs to retain proof that it covered the difference?

Thank you!

Well, that would leave the only error on the CD in the payments table and your total of payments is probably overstated. That would not be considered a clerical error and the closing fees that the borrower paid are not changing. Those are the only two occurrences in which a post-closing CD can be used to cure a disclosure error. Anything else is really up to you, but will not cure the regulatory violation. Whether you choose to issue a courtesy post-closing CD would be up to you or your investor, if any.