Thank you!

Randy, would you mind expounding on this:
?????

When else would you have one? Other than a rate lock event, maybe?

A changed circumstance could be any number of things maybe none of which increase a fee.

Do you mean the only time you should redisclose is when a changed circumstance occurs is when a fee increases?

Went back and re-read the latter part of this thread. Adding someone is not a CC unless added fees [credit report] are involved. Loan amounts going down has never been a CC event!

Absolutely!

{Although I'd change 'should' to 'have to'} in the above quote...but I surely don't re-issue for a loan amount going down...holy cow the extra work/time involved with that!

Everything else would be an informational LE. There are no other mandatory requirements to issue a revised LE, except if you choose to reset your fee tolerances. There is no harm in issuing an informational LE at anytime, but there are no other circumstances outlined in the regulation that triggers a revised LE. Investors, however, may have additional requirements.

All I'm getting at is that the statement that 'a changed circumstance only involves an increase in fees' is, on the face of it, misleading.
A changed circumstance is what allows a bank to increase the corresponding fee and redisclose.
For the sake of others reading this thread, I think the statement Randy made needed to be explained.

Now you have me confused. "Changed circumstances" is a defined term in the regulation.

1026.19(e)(iv)(A) Changed circumstance affecting settlement charges. Changed circumstances cause the estimated charges to increase.....

How is what I said misleading? "A changed circumstance only involves an increase in fees." If you have no increase in fees - you have no changed circumstance. I fail to see how this statement is misleading on the context of this thread. Adding a co-borrower is not a changed circumstance if there is no increase in fee, such as the need to add a credit report fee. Issuing an LE without an increase in fees equates to issuing a informational LE to the applicants.

8.2 What is a “changed circumstance”? (§ 1026.19(e)(3)(iv)(A))
A changed circumstance for purposes of a revised Loan Estimate is:
 An extraordinary event beyond the control of any interested party or other unexpected event specific to the consumer or transaction (§ 1026.19(e)(3)(iv)(A)(1));
 Information specific to the consumer or transaction that the creditor relied upon when providing the Loan Estimate and that was inaccurate or changed after the disclosures were provided (§ 1026.19(e)(3)(iv)(A)(2)); or
 New information specific to the consumer or transaction that the creditor did not rely on when providing the Loan Estimate. (§ 1026.19(e)(3)(iv)(A)(3))

I do not agree with this statement. Further I felt that it was misleading. You can have changed circumstances that don't affect fees at all.
Maybe I'm spiting hairs but I think it's an important distinction to make for others reading this now or in the future.

This probably doesn't help explain anything to anyone but me, but....

If a "change" causes an increase in fees, I call it a "changed circumstance" which causes the lender to have to complete an internal form explaining the "circumstance" and what fees the circumstance will increase.

If it's a "change" that doesn't affect fees, and the lender wants to issue what Randy referred to as an "informational LE" then it's just a "change".....not a "changed circumstance" per regulation.

Splitting hairs? Probably.

Swiggles... you are EXACTLY correct!!! Bothers me greatly when people use the phrase "change in circumstance", when there is just a "change". "Change in Circumstance" is specifically used when there is a valid reason to issue a revised LE.

So for example, the loan amount change. Just because there was a loan amount change, that doesn't mean it was necessarily a "change in circumstance' specific related to a change in fees which allow for a revised LE.

In those cases, it's just a change. It's a memo to the loan file.....