The determination of whether there is any need for a tolerance "cure" is a comparison between the costs on the loan estimate (adjusted by any timely revised loan estimate or closing disclosure in the case of a changed circumstance) and the actual costs paid by the consumer (borrower).
If the LE shows the cost for one credit bureau pull and the consumer pays only that cost, there is no tolerance violation. The cost of the second credit bureau pull, which was paid for by the bank, has to be shown on the closing disclosure (because all costs related to the transaction must be disclosed, regardless of who pays them). Disclosing them as paid by the lender in the "Paid by Others" column fulfills the requirement to show all costs, and also shows the consumer did not pay for it.
So there is no tolerance "cure" required because there is no tolerance violation. The consumer is not owed a refund.
John S. Burnett
Fighting for Compliance since 1976
Bankers' Threads User #8