LO grabbed old HELOC application disclosure and gave to applicant. Origination and release fees have changed and are slightly higher. Correct disclosure with current fees provided prior to closing. Do we eat the difference between the old and new fees or can we charge borrower with the new fees?

No - I am sure the original disclosure had: A statement that, if a disclosed term changes (other than a change due to fluctuations in the index in a variable-rate plan) prior to opening the plan and the consumer therefore elects not to open the plan, the consumer may receive a refund of all fees paid in connection with the application.

Other than that, it would just have been a disclosure error. Get rid of those old disclosures