If you thought the HVCC was a pain, wait until the new H.E.R.A. Truth In Lending rules take effect July 30th. Under the new rules the final TIL's APR cannot vary by more than .125% UP or DOWN from the initial disclosure. If it does, the TIL must be re-disclosed to the borrower and closing cannot take place until 3 business days AFTER the borrower RECEIVES the disclosure.
Since some APR fees (like per diem interest) are not determined until the closing date is set, this is sure to create problems. Typically final fees are collected a day or two before closing and the closing package is prepared and sent off to the title company or closing attorney.
Under the new rules, if the APR was off, a new TIL would have to be prepared in order to re-disclose the APR and closing would have to be postponed to satisfy the waiting period.
This is all in the name of consumer protection. Explain that to your home seller when you have to cancel the closing.