Answer:
From Regulation Z Section 1026.19(a)(2)(ii):
(ii) If the annual percentage rate disclosed under paragraph (a)(1)(i) of this section becomes inaccurate, as defined in Section 1026.22, the creditor shall provide corrected disclosures with all changed terms....
It would be my opinion that the "courtesy" ETIL was not issued under paragraph (a)(1)(i) or under (a)(2)(ii) therefore you would need to compare the APR to the original ETIL disclosure.
First published on BankersOnline.com 3/12/12