Help! Loan officer wants written proof that an understated APR and understated Finance charge on a residential mortgage loan requires reimbursement. Understatements are not within Reg acceptable range. The request was "show me in the law where we have to reimburse".

I'd review 130(a) and (b) of the TILA itself. Reimbursements are what protects you against big losses in the event of litigation. You also have a 60 day clock.

Imagine standing in front of a jury of fee paying bank customers and the plaintiffs attorney is speaking:
"You were wrong, and this should cost you," or
"You knew you were wrong, chose not to do anything about it and now it will really cost you."

Thanks Andy.
The LO says that the customer is willing to sign an affidavit of no harm without restitution and therefore he believes we are in the clear. Any thoughts?

Sure. I sign today. A year from now I have problems. I speak with a good attorney who says "they can't take away rights you have under the law that way. The bad news is my fee just went way up. The good news is, you won't have to pay it, your old bank will."

You might get around the problem with a refi. But I don't think a waiver would do.

Andy, is there a statute of limitations on making reimbursements for understated finance charges? I was once told by a compliance trainor that if a lender discovers an error in year 29 of a 30-year loan, he fails to make restitution at his own peril. What is the rule or law on this question?

Go back to the Act itself. I'm not sure if it extinguishes with anything other than the debts being paid.