This will depend on your regulator. The FDIC has taken the stance that if the APR is out of tolerance either up or down then a revised ETIL must be issued. This is also from the Philadelphia Fed.
New TIL Disclosures Required 3 Business Days?
Are new TIL disclosures required 3 business days prior to closing the transaction if the interest rate and associated APR go DOWN by more than 1/8 of 1%. For instance 4.50% was disclosed initially, but rates dropped and now rate is at 4.00%?
First published on 11/17/2014