Yes. That is when it starts, with internalized faith. That is what I said.
And as sinful thoughts in the heart can defile a man, (Mk. 7:21-23) so hearts are purified by faith, and Abraham believed God and his counted was counted for righteousness, which God does to him that worketh not but believeth, with a faith that is active by nature. And the preparatory work in one heart which precedes justification by sola fide is also by the grace of God.
Do penance, and be baptized every one of you in the name of Jesus Christ, for the remission of your sins: and you shall receive the gift of the Holy Ghost. (Acts 2:38)
The disagreement here is what this requires. There is no do as in doing works of repentance prior to baptism that day, nor does the context indicate that they did such, but repented of unbelief and the heart behind that hour and same day, and were baptised in faith, which would results in doing works which correspond to repentance, (Acts 26:20) which again, distinguishes the internal change from its external consequence. This is no mere intellectual exercise, again, any more than sins of the heart are. If penance means coming to God out of a broken heart and contrite spirit, signifying repentance, and which God promises to look to and save, (Psa. 34:18; Is. 66:2) which is a work of grace, and out of which actions will result then it is a Scriptural need, and Sola fide presumes faith comes out of such a heart. But if you require that evident formal or prescribed acts of contrition must always be exercised before forgiveness, though such may be seen, then you are fostering legalism and denying contritio caritate perfecta and baptism by desire. Souls must obey some light before they can be saved, but even choosing to hear a gospel message can be evidence of such, and God knows the heart.
"without first afflicting themselves in penitential suffering" is your arbitrary qualification on what "do penance" must in your opinion, mean.
It is you who provided examples, such as the criminal on the cross.
 And he commanded us to preach to the people, and to testify that it is he who was appointed by God, to be judge of the living and of the dead.  To him all the prophets give testimony, that by his name all receive remission of sins, who believe in him.  While Peter was yet speaking these words, the Holy Ghost fell on all them that heard the word.  And the faithful of the circumcision, who came with Peter, were astonished, for that the grace of the Holy Ghost was poured out upon the Gentiles also. (Acts 10)
I don't see anything about salvation predicated or not predicated on penance in this passage, other than "judging" ordinarily implies some form of temporal punishment.
It was predicated upon having the aforementioned heart, and which at least Cornelius evidenced, consistent with the preparatory work sola fide recognizes, yet that did not justify him, but Peter said God purified their hearts by faith, (Acts 15:9) being born again before baptism.
 And a certain woman named Lydia, a seller of purple, of the city of Thyatira, one that worshipped God, did hear: whose heart the Lord opened to attend to those things which were said by Paul.  And when she was baptized, and her household, she besought us, saying: If you have judged me to be faithful to the Lord, come into my house, and abide there. And she constrained us. (Acts 16)
Yes, but baptism of an adult mandates penance (Acts 2:38).
As defined above.
the problem is your interpretation places James in direct contradiction to Moses and Paul
No it doesn't because St. Paul never taught "justification [...] to be procured by faith not merit". He taught that is if offered for no merit of ours, -- that is, offered in grace -- but he never taught that it is apprehended by faith alone (Eph 2:5-10).
See prior recent comments, regarding making not by works of righteous or without works or works apart from the law, or by the law and to him that worketh not but beleiveth to mean the unGodly did works of love which first justified them.
despite your incongruous attempt to set declarative righteousness in opposition to being regenerated, there is no conflict between them
Well, so long that you understand that regeneration is real and not merely imputed in some formal sense, I will not argue over words. There is a brand of Protestantism that reads "imputed" as in opposition to transformative justification; that one is in error.
Sola fide holds that regeneration is real and not merely imputed in some formal sense, and is concomitant with justification but that justification is not based upon ones interior holiness, but a faith that is counted for righteousness, as Scripture clearly states. (Rm. 4:3,6) But which again, results in practical outworking enabled by regeneration. The main thing to me is that it happens, and that morally destitute man rests in the Lord Christ as His Savior, and thus responds to Him as Lord.
Rome's literalizing the allegorical in the Lord's supper is manifestly self-refuting.
I don't know how you can call anything that requires kilobytes of inane commentary "refuting". I would think that reading the actual gospel which says things like "flesh indeed" and "this is my body" is self-evident.
What is self evident is that it is not comprehensive analysis but such superficial rendering which ignores obvious allegory that is inane: Showing a lack of intelligence or thought; stupid and silly. That kosher disciples would unquestioningly eat flesh and drink blood, understanding what it was, while Peter was aghast that Jesus would even wash his feet, and protested violating kosher law, while the abundant allegorical use of eating easily conforms this and Jn. 6 to Scripture. Otherwise one might as well conclude that the Israelite were cannibals, (Num. 14:9) and that Jeremiah ate scrolls, (Jer. 15:16) or that Jesus did likewise, (Jn. 6:57; cf. Mt. 4:4) and that David experienced transubstantiation. (1Chron. 11:17-19) And which explains the allegorical use in the New Testament. But as if have already shown this extensively, and you are not allowed to see anything different from what Rome teaches, then extended discourse can merely be tactic to take up my time.
as for weekly service with a priest with his back turned to the people, that is not in any description of the New Testament church.
That is consistent with the Mass being a sacrifice to God (not a repeated sacrifice but a sacrifice), where the priest leads the congregation rather than opposes it. It also excludes the false understanding of priesthood as ministry to men. But I agree that there is no fixed position of the priest that would be apparent in the scripture, and in fact, like it or not, most Masses nowadays are served ad populum.
Again, apart from apostles, elders/bishops were the pastors of the church, being one office not two, (Titus 1:5-7) and were not a separate class of sacerdotal priests. All believers engage in sacrifice, (Rm. and there is nothing in all the instructions given to pastors that teaches they are to instrumentally transubstantiate bread and wine into Jesus corporeal flesh, but are to be and work to make the church an manifestation of Christ by their character and works.
Shows that is it not sola fide. Nor is it necessarily in one heart; crossing the desert involved also at least two legs.
There is no do as in doing works of repentance prior to baptism that day [ ] but repented of unbelief and the heart behind that hour and same day, and were baptised in faith
Possibly, in the case described. Other cases of conversion described also outward works, such as giving away possessions (Luke 19:8). The point of penance is to do what is necessary for effective rependance as well as change internally. Your argument here is again, like your building Sola Fide on Gen 15, based on picking a verse you like and discarding the rest on the same subject.
if you require that evident formal or prescribed acts of contrition must always be exercised before forgiveness, though such may be seen, then you are fostering legalism
Authentic Christianity does not require that penance be done when there is nothing to repent of.
It was predicated upon having the aforementioned heart, and which at least Cornelius evidenced, consistent with the preparatory work sola fide recognizes, yet that did not justify him
That justified him enough to seek baptism. Justification is a process. Preparatory work is a part of it. We are not justified by faith alone.
Sola fide holds that regeneration is real and not merely imputed in some formal sense
To borrow the colorful language of one political operative, I could probably drag a dollar through some Protestant trailer park and find you plenty who disagree with you here. Same in general on the conception of sola fide that nevertheless involves preparatory work and out of which actions result and which is never alone.
the abundant allegorical use of eating easily conforms this
Abundant allegorical use of eating prefigures the actual Eucharistic Feast the literal nature of which is explained in John 6. You realize that allegories in the Bible are there to point to realities, rather than to provide amusement, do you not?
elders/bishops were the pastors of the church, being one office not two, (Titus 1:5-7) and were not a separate class of sacerdotal priests
True, but the office of the priest was inherent to that. In other words, a bishop is also a priest, but the reverse is not always true. The separation between bishops and parish priests came about with the growth of parishes. If, hypothetically, the Church shrinks so that in any given town every Christian can fit in the cathedral, only the bishops will be priests once again, like in the Old Church.