Ok we have to reimburse on a loan because the fees financed were not correctly shown on the initial periodic statement. I looked at the Joint Statement of Policy which is clear as mud... Also FIL 20-98 and the most recent exam handbook.... Anyone had any experience calculating reimbursements on these. My thought is we could just refund the fees and we would be good, but it seems to me since there is an accuracy tolerance we should take advantage of it at least.

Help would be appreciated.

Do you have an APR violation??