I came to the conclusion awhile back that unless the clairify/change their minds/or whatever, in an official document (which there are two of) it doesn't count.

No, I don't think it's automatically true just because someone said it. But I also don't think it's true just because an email came from David Friend or Andrew Fay. Granted it holds more weight, but like RR Joker said - unless it's written in some kind of official document I don't think we can consider anything accurate. Even if it did have a name on it, would I then be expected to find out what exactly this person does at HUD and whether they are in a position to answer such questions? Where does it end? If they are answering the email then obviously HUD has given them the authority to do so.

And I do think it gives me a leg to stand on with examiners. I think we all can agree that the regulation doesn't REQUIRE a GFE to be re-disclosed if the loan amount changes. The fact that I have an email from HUD that confirms that just gives me a little extra ammunition. Can the examiners disagree with me? Certainly, but at least I've done my due diligence and followed HUDs own procedures for getting questions answered.

Q: If all or a portion of the charge in Block 1 is calculated as a percentage of the loan amount, and the loan amount changes, can the loan originator issue a revised GFE with an updated charge in Block 1?
A: Yes, but only if issuance of a revised GFE is permissible under 24 CFR § 3500.7(f). In particular, if the loan amount changes and all or a portion of Block 1 is calculated as a percentage of the loan amount, then that portion in Block 1 may be recalculated.

I think it's answered plainly enough in the above Q&A, isn't it?

Well...not really. That FAQ is saying that the origination fee may be recalculated, so it's not really addressing whether a new GFE has to be re-disclosed when the loan amount changes.

Look, I think the regulation itself is clear that a new GFE isn't required when the loan amount changes. I'm not arguing that, I'm agreeing with it. The only reason I emailed HUD in the first place is because we had investors that were suspending our files because the loan amount on the GFE didn't match the loan amount on the HUD. And that's why I don't think it's a big deal that I use the email without a name - because it supports the regulation. Someone above posted that HUD is saying a new GFE must be re-disclosed when the loan amount changed, and all I was trying to do was show that I had received a different response from HUD. Simply showing one more case where HUD isn't consistent and now I suddenly feel like I'm trying to defend myself. Guess I learned my lesson.

MN, don't take it personally. Hang in there and keep posting. We value your input. And we've all had this level of frustration. I've regularly been mixing it up with Dan lately as you may have noticed. It's a learning and growing situation. If we all pool our resources and our HUD emails, we may make an iota of sense out of this constantly evolving pile of RESPA poo that HUD keeps shoveling in different piles as the whim hits them.

That was my point with that reference, MN...it says you "may"...it doesn't say you "must".

Generally speaking, the only real change that happens with a loan amount change is the origination charges, recording and tax-based stuff. You can revise for any of those reasons...or you can leave it be, either way.

Having said that. Investor's are unique entities and they have their own agenda and rules of which sometimes you have no choice but to follow.

Ok, I'm not disagreeing with you that issuing a new GFE isn't required. I never said I thought it was - I was just posting the response that I got from HUD that was contrary to what someone else got. I'm not sure why you're trying to convince me it's not required???

And trust me, I realize that investors get to make some of their own rules - we deal with it all the time. However I had an investor telling me it was required by regulation. I was simply trying to get some more backup by emailing HUD. The investor did eventually back down.

Who knows!

But in the end...I'm glad you won!

Try to remember.....these are discussions.....not arguments.....I've been squashed before, but there are no mean intentions....at least in these professional forums. Just stay away from the cooler! That's a whole nuther ballgame.