If you have a csustomer that applies for a real estate loan in the amount of $45,000 (debt consolidation)and you early disclosures were preapared on that amount but when the appraisal comes back there is room for additional money so you increase the loan amount to $48,000 do you need to redisclose?

No. I generally recommend redisclosure If their is a substantial change...what you have described would not, IMHO, be considered substantial.

If there is a substantial change then I too would recommend re-disclosing, however it should be made clear there is no regulatory requirement to re-disclose the GFE or the ETIL regardless of the change. Those disclosures are made based on information known at the time the application was received and they are not required for every negotiated change to the loan request during the application process. The one exception would be changing from a fixed rate product to a variable rate product. In that case you must furnish the variable rate disclosures.


A clarifying comment. If the change throws the ETIL out of the allowable tolerance for the transaction then you must provide an accurate final TIL, but there is no requirement to re-issue the early TIL.

I agree with everyone's advice about redisclosing ETILs. Unless the customer requests one or you see some value in it, you can skip ahead to the final TIL. As a general rule, you should always do a final TIL. Mandatory final TILs are cheap insurance and will catch the type of changes you described. By disclosing the deal exactly as consummated, you make it MUCH easier to audit the documents. Easier audits mean time and money saved.