consumer loans collateralized by CDs that are essentially open-ended
I'm confused. You said that the error involves the disclosed "finance charge," so apparently this question relates to Regulation Z. What do you mean by "open-ended"...and is this a description of the loans, the CDs, or both? If you mean that the "loans" meet the definition of "open-end credit" found in Section 1026.2(a)(20), then there is one disclosure scheme, but if the "loans" are actually "closed-end credit" (anything other than "open-end credit"), then there's an entirely different disclosure scheme. Before we can help you decide how to correct an error (violation?), we first have to agree on what should have been
disclosed. Also, you'll have to be more specific about what "disclosed incorrectly" means. Overstatements aren't usually a big deal, but understatements are subject to additional statutory and supervisory agency standards.