How is everyone handling the requirement to keep track of changed circumstances and redisclosing?

I don't want to overcomplicate things but I wonder if our files should all have a simple log and if we need it, we have it and if we don't, it will just stay in the file blank?

I am so afraid our processors or loan officers will miss something!

we are planning to track it electronically, but with the same thought that you have. If there is a changed circumstance, we want it detailed CLEARLY in the file what the change was and why we deemed it to be a changed circumstance and the action we took as a result.

Ditto Manylayers. I have instructed our disclsoure processor not to redisclose without proper documentation and my approval. Our LOS is set up so after the first disclosure is sent, a new one can not be generated without supervisory override.

Our LOS is tracking this for us. When we change the GFE we get a box that pops up for re-disclosure purpose, then it lists the HUD defined reasons. We can print the GFE history for the file which is backed up with the proper documentation.

We too will require a description sheet to be included in the file detailing the reasoning for the additional GFE.

Just Jay----would you be willing to share your description sheet for details on your changed circumstances???

no formal form... either an email, basic word doc, or a printout from the notepad on the LOS.

When I audit loan files this year, I will be looking for something (in the system, in the loan file) that will explain the transaction to me (initial GFE, revised GFE and why, dates, etc.)

Without some sort of documentation you won't know what occurred or why it occurred when you have to look at an older file if questions arise from the customer (or their attorney), an auditor or an examiner.

We sell loans on the secondary market to a major west coast bank; they have a changed circumstances sheet that must be placed with the GFE in each case to document the blessed event.