I would like to get an opinion about the dates on a redisclosed GFE...We initally disclosed the GFE to the customer and inserted the dates (10 business days after) for number 1 and 2 on the first page. The fees and loan amount changed causing the GFE to be reissued...My question is on the reissued GFE the dates in numbers 1 and 2; would they be the same date as the reissued date? Or would they be 3 days after this date? or the same as the initial GFE?
I have asked 3 different employees and received 3 different answers.

In box 1, unless the rate is locked, we use the date that the re-disclosed GFE is issued. We keep box 2 the original date as they have already expressed intent to proceed.

There should be no opinions on this.
The FAQ tells you exactly how to complete the dates section.
Start reading on p.22.


btw, the fees changing is NOT a valid changed circumstance under which to issue a redisclosed GFE. A change in loan amount is a valid CC. Your redisclosed GFE can ONLY change the fees that are directly tied to the loan amount.

And, fwiw, if the loan amount went down, I wouldn't be redisclosing at all. You don't have to and doing so narrows the tolerance margins so it's not to your bank's advantage.

I couldn't find anything about the dates in the "Getting it Right" section.
Is there somewhere this would be located in the Regulation?

Getting It Right is Reg C for HMDA.
You need the RESPA FAQ .

Thanks...I am looking at the FAQs now.

@ Truffle Royale - re: And, fwiw, if the loan amount went down, I wouldn't be re-disclosing at all. You don't have to and doing so narrows the tolerance margins so it's not to your bank's advantage.

If everything went down and the ONLY thing that changed was the locking in of the rate, based on the FAQ, page 8, #19 - doesn’t that state you MUST issue a revised GFE "within 3 days of the interest rate lock reflecting the date that the interest rate is good through in Line 1 and "N/A" in Line 4 of the "Important dates" section of the GFE."
So, you MUST re-disclose, correct? Just the GFE of course.

We also get multiple opinions on this. Thanks in advance

Not TR (I think she's Out of Town)

Yes, that is the one time you must re-disclose.

(Reading on the road)
The OP only said the loan amount went down, not that the rate locked.
imho, and in light of all the trouble we bankers have understanding GFEs and redisclosures, peppering the borrower with numerous GFEs only confuses them. Borrowers should be told if another cost will be added (think completion cert or escrow waiver) because something changed from time of application. So i tend to only redisclose if I need to capture a larger fee that may throw me out of tolerance and when the rate locks as mandated by the Reg.

thanks for the responses. I think that's a "YES" from TR ^^^^^^. Only redisclose to capture a larger fee and OR??? when the rate is locked??

Yes, and/OR. The rate lock is required...the higher fee due to a COC is just up to you.

Thanks so much!!

I have heard many times that the date in Line 2 of the Important Dates section never changes. Is it possible that the date might change in the following circumstance?

GFE Provided 01/01/2015 and rate is floating with a Line 2 date of 01/15/2015
Rate is locked on 01/02/2015 so re-disclosures are required within three business days.
Re-disclosures are issued on Monday 05/05/2015.
Intent to proceed received on 05/08/2015

Would Line 2 change to 01/19/2015 for the GFE re-disclosed for rate lock since intent to proceed was not yet obtained from the consumer, but re-disclosure was required? Is this even possible? Thank you!

Nope. Since you provided the GFE on 1/1/2015, line 2 is always going to stay 1/15/2015. Intent to proceed has nothing to do with the dates.

Thanks Matt,

Let me take this a step further. HUD FAQ #12

12) Q: If a revised GFE is provided due to changed circumstances or a borrower requested change, must a loan originator complete Line 2 in the “Important Dates” section on the revised GFE if the shopping period has ended and the borrower has already expressed intent to continue with the application?

A: Yes, the loan originator must complete Line 2 in the “Important dates” section with the same date from the last GFE. The borrower is not required to re-indicate the intent to proceed with the revised GFE because the borrower has previously expressed an intent to move forward with the transaction.

So the FAQ from HUD is not saying that intent to proceed is necessary? I was interpreting this as intent to proceed was necessary for this date to stay the same. It made since to me that if the borrower had not yet expressed the intent to proceed with the terms in the original GFE and the redisclosure happened prior to intent to proceed that the settlement costs of the new GFE would need to be good for 10 days. I can see why that would not be the case as well since the 10 day shopping window was started on 01/01/2015...

The above example is not necessarily explicitly addressed by this FAQ response either. In this example, the shopping period has not ended and the borrower has not expressed their intent to proceed (which it sounds like may not be necessary)...

Are there any potentially negative consequences of getting this date wrong on revised Good Faith Estimates?