So...an internal review revealed that the frontline staff has not been changing the credit report fees as they complete the CD for delivery. They have been leaving the fee, unchanged, as it was disclosed on the LE(s). A majority of the files show that the fee invoiced to my FI was much higher than charged to the consumer on the CD. So there has not been many identified that require a refund. We are working on the revised CD that require the refund...
My question is, is my FI required to re-disclose a corrected/accurate CD for all of the CDs that were disclosed and charged the lesser amount, as my FI lender paid the difference? The CD's did not show the lender paid portion...

Thank you-

No change to the amount actually paid by the consumer - no post-closing CD:

(iii) Changes due to events occurring after consummation. If during the 30-day period following consummation, an event in connection with the settlement of the transaction occurs that causes the disclosures required under paragraph (f)(1)(i) of this section to become inaccurate, and such inaccuracy results in a change to an amount actually paid by the consumer from that amount disclosed under paragraph (f)(1)(i) of this section, the creditor shall deliver or place in the mail corrected disclosures not later than 30 days after receiving information sufficient to establish that such event has occurred.

Thank you, Randy :-)