New comment 19 (e)(3)(i)-7 explains that although § § 1026.37 (o)(4) and 1026.38 (t)(4) require that the dollar amounts of certain charges disclosed
on the Loan Estimate and Closing Disclosure, respectively, be rounded to the nearest whole dollar, to conduct the good faith analysis under § 1026.19 (e)(3)(i) and (ii), the creditor should use
unrounded numbers to compare the actual charge paid by or imposed
on the consumer for a settlement service with the estimated cost of the service.