The payoff of an existing loan on a refi was disclosed at closing as $32,584. The actual payoff amount was $32,452.

I have a settlement agent who disagrees that an incorrect payoff amount of the existing loan (on CD without seller) triggers corrected disclosures post closing. He gave the difference to the customer but doesn't think a revised CD is required. Anyone agree or disagree?

Doesn't matter what the settlement agent thinks. The onus is on you. The Closing Disclosure must reflect the ACTUAL COSTS. Therefore a corrected CD should be issued.
Here we send the corrected CD, the check and a cover letter explaining what happened. Copies are kept in our file to show examiners.

You'd think at some point the settlement agent attorneys and title companies would give up arguing and just comply.

Ha. Most of the settlement agents we work with know not to do ANYTHING without clearing it with us first. Returning monies without my bank's ok would start a small war.

Agreed - a corrected disclosure needs to be sent. And agree with Truffle that "this means war!"