Answer:
Neither RESPA nor Reg Z require redisclosure of the early disclosures unless the product itself changes. The "corrections" to these disclosures are made on the HUD1 and the final TIL.
First published on BankersOnline.com 5/20/02
Extending Commitments, Extra Fees & Disclosures
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Question:
Customer's commitment expired. When we extended the commitment, we ran a new credit report. However, the fee for the extra report was never disclosed on our original disclosures. Should we have redisclosed when a new commitment was issued because of the extra fee?
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