We need clarification on a tolerance issue regarding LE and CD fees.
Based on the regulation, all fees on the LE must be rounded as stated below:
Paragraph 37(o)(4)(i)(A).
1. Rounding of dollar amounts.
Section 1026.37(o)(4)(i)(A) requires that certain dollar amounts be rounded to the nearest whole dollar. For example, pursuant to § 1026.37(o)(4)(i)(A), periodic mortgage insurance payments of $164.50 are required to be disclosed under § 1026.37(c)(2)(ii) as $165. However, if the periodic mortgage insurance payment equaled $164.49, the creditor would disclose $164.
We need to know how to handle this when we know and enter an exact fee, it is rounded down on the LE and then it appears we under disclosed on the LE and need to issue a tolerance due to the rounding.
For example, the credit report is $53.15. We know it, enter it in system, but LE regulation forces system to round to $53. When we issue the CD at $53.15 it appears we under disclosed by $.15 cents; hence appearing to have to issue a tolerance cure of $.15.
Why would we need to issue a $.15 credit, when we in good faith entered the exact cost? Are we interpreting the regulation correctly?
Thank you in advance for any feedback!