I know we can't redisclose the LE unless the combined amount of changes increases more than 10%. However, does this 10% threshold apply if we are not increasing already disclosed charges, but in fact adding a brand new charge that was not on the original LE? Seems like we would have to disclose that charge by itself even if it was only say 9% simply so the borrower would know we were going to charge a new fee. I know this is addressed somewhere, but I'm fried and just can't find the right search word combination to get me there today. Thanks!

"I know we can't redisclose the LE unless the combined amount of changes increases more than 10%."

That is not a true statement. It is just that it doesn't do anything for the creditor. You can always reissue, but it doesn't reset your tolerances. So the more pieces of paper issued, the greater chance for mistakes.

That said, the new fee goes in the 10% aggregate bucket just like any other increase in previously disclosed fees.

One reason to consider doing a revised LE in these circumstances is to get the new service on the "shoppable" list (assuming it's a service you'll let the consumer shop for). According to today's 45 minute CFPB webinar, the creditor may issue a revised "shopping list" that adds the new service(s) and at least one provider for each to the list previously provided, or sends a new list of just the new service(s) and provider(s) in order to get these services subject to the 10% increase limit group. Without sending the updated or new list, you cannot comply with the requirements for making these services shoppable, so they would default to the 0% increase level.

If the added service doesn't add 10% or more to the aggregate bucket, you will not have reset the basis for the LE charges for the group, but you will have at least gotten the new service(s) into that group for analysis.

Thanks rlcarey and John Burnett. By my "can't redisclose the LE..." sentence, I was actually stating the policy we were going to try to follow so in looking at a loan file we could clearly see what our base tolerance was and avoid as many "mistakes" as possible. Wishful thinking though because I had not considered the revised shopping list issue that was addressed today. One thought, would it be possible to give the borrower a shopping list that included providers for every possible service we could think of up front, even if the borrower doesn't need it and still be covered? That way if we had to add a charge for a changed circumstance later they have already received a suitable provider in the list they got up front?

Just two cents, and it ain't worth much, but isn't that an awful lot of work to produce and keep current on the off chance that you will have a loan once in a while that will have a changed circumstance adding another service?