Q: Is a new three-day waiting period required if the APR decreases?
A: The TILA-RESPA Rule requires an additional three-business-day-waiting period if the APR becomes inaccurate as defined in § 1026.22(a). It is possible that an overstated APR would be inaccurate under § 1026.22(a) of Regulation Z. The TILA-RESPA Rule did not change this section of Regulation Z. For additional information on when the APR becomes inaccurate, see § 1026.22(a), noting that § 1026.22(a)(4) contains special APR accuracy rules for mortgage loans. Additional guidance on the accuracy of overstated APR is available in the Federal Reserve’s Consumer Compliance Outlook, First Quarter 2011 at www.consumercomplianceoutlook.org/2011/first-quarter/mortgage-disclosure-improvement-act/.