I am currently conducting an audit of our mortgage loans. I came across two loans where the amount financed has been figured incorrectly (overstated)on both the early TIL and final TIL. This in turn has overstated the finance charge and the APR and the total payments. What should be done to correct this?

Refer to 1026.22(a)(5)(ii). You should be OK.

Maybe I'm misreading the facts of this case, but when the AF is overstated, that usually means the FC and APR are understated. The TOP should not be affected. Can you provide the numbers and additional explanation of the source of the problem?

I apologize, the amount financed is understated on each loan. I see no tolerance for the Amount Financed. This incorrect amount has thus overstated the APR and Finance Charges. These are both mortgage loans - one a purchase, one a refi. I believe this error is due to user input and not necessarily a system error.

Do I need to take further steps to correct this with our customers? It will be addressed with our loan operations department.