Answer:
After closing, you are no longer operating under Reg Z.
Now, anything you do becomes remedial action and Section 130 of the TILA spells out the only remedies for violations. In all cases, the violation (and related civil liability) extends until you have reimbursed any FC or APR understatement. Redisclosure without reimbursement only moves you a step closer to the liability. The post-closing disclosure becomes an admission of guilt and you have no defense.
First published on BankersOnline.com 1/3/05
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