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A lender discovers that the APR disclosed on the Closing Disclosure is 0.20 percentage points higher than the actual APR. What action is required under TILA?

Correct Answer

C) Provide corrected disclosures but may proceed with closing immediately

Under TILA/Regulation Z Section 1026.22, when the disclosed APR is higher than the actual APR by more than 0.125 percentage points, corrected disclosures must be provided. However, since the disclosed APR overstates the actual cost to the borrower, there is no additional waiting period required before consummation.

Answer Options
A
No action required as this is within tolerance
B
Provide corrected disclosures and wait 3 business days before consummation
C
Provide corrected disclosures but may proceed with closing immediately
D
Pay the borrower compensation for the inaccurate disclosure

Why This Is the Correct Answer

Under TILA/Regulation Z Section 1026.22, when the disclosed APR is higher than the actual APR by more than 0.125 percentage points, corrected disclosures must be provided. However, since the disclosed APR overstates the actual cost to the borrower, there is no additional waiting period required before consummation.

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