In internal audit uncovered that when we are disclosing that the estimate for all other settlement charges is available through _________(date), we are not always giving 10 business days. I think there has been an issue with our vendor. What are the repercussions or penalties for not providing 10 business days? Other than getting our software fixed, what, if anything, should we do with the GFEs that we found?

How is it that this is only happening some times and not always?
You cannot go back and correct this.
You can only reissue with a valid changed circumstance and bank error is never a valid cc.
At this point all you can do is document the error and not that you are correcting going forward.
Going forward until you're sure you're always getting it right, I'd also review every GFE (soon to be LE) prior to sending it out.

Thank you, Truffle. The way it was happening sometimes, after further details, is that the vendor defaulted to the wrong date, and all but one loan processor knew to change the date to the corrected date. We will document the error, and the GFEs will be reviewed going forward. That being said, other than criticism from a compliance exam, are there specific penalties under the regulation, or is this a "no cost loan"?

Due to editing restraints in the new BOL website, I'm posting again here to say that in the fourth sentence, 'not' should be 'note'.

As to your last question, the only time you'd have a no cost loan would be if you didn't give the GFE at all.
An error, especially one like this that doesn't impact fees at all, does not wipe off everything else in the GFE.
Yes, you'll likely be criticized but documenting the error and the cure will likely mitigate any other fall out.

Thanks very much for your help.

Hi Truffle - to expand on your statement "the only time you'd have a no cost loan would be if you didn't give the GFE at all."

What if the FI gives the GFE, but not within 3 days from application? Does the FI still issue a no cost loan? Or could the FI work with the tolerance set with the initial GFE (even though outside the 3 day window)...I ask we had an issue where an LO quit, and by the time another LO picked up the file, we had an app for a week. We documented the file and disclosed. But should it have been disclosed as a no-cost loan?

Thank you!

There's a lot of discussion in this forum on this topic. The answers fall on both sides.
Generally the consensus seemed to be if it was a day or so late, you could still give the GFE and go with the costs shown.
If it went more than that, a number of us would bite the bullet and give the loan no cost.
It's water under the bridge for you now but since you asked for my opinion, I would have done this as a no cost loan due to it being a bank error. I wouldn't want to have to defend this in an exam. jmho

I understand - Thank you for your opinion. It makes sense to me.