We are working on a loan that had non-married co-borrowers. It is my understanding that the Homeownership Counseling Disclosure may be given to just the primary borrower. Which we did. Then for underwriting reasons, the primary borrower was removed from the loan and the co-borrower will become the primary borrower. However, this person was never sent the Homeownership Counseling form and we are long past the three days from application. Should we provide a new homeownership counseling form to the new primary borrower?

It couldn't hurt to do so. And you complied with the requirement with respect to the primary applicant earlier.