Our discounted initial rate was disclosed on the TIL for the entire term instead of just during the discount period, which has resulted in an understated APR. I ran it through the Aprwin calc. adjusting the second payment stream to the fully index rate. The result is the finance charge and the APR are understated and qualify for reimbursement. Do I need to reimburse for the entire loan term, which is a rather large amount? Any help would be appreciated.

I believe you only have to reimburse up until the first scheduled rate adjustment, i.e., if the first rate adjustment is after one year, you only reimburse for that one year period.

Lee is correct. When entering the reimbursement data, enter the number of payments in the initial period for the number of payments made. That will get you where you need to be.

Remember, to totally eliminate your civil liability, you should reimburse at a zero tolerance level.

Thanks for the responses. When I enter the number of payments it reduces the payment method amounts, however the finance charge adjustment remains the same. I get lump sum/payment reduction method: payments 1-60 ($165.75)and lump sum method: payments 1-360 ($585.14) and finance charge adjustment: ($9,098.48). Do I take the 165.00 times 60 payments which equals 9,945, and reimburse that amount, since it is larger than the finance charge adjustment. This is my first experience with this, so I appreciate the help.