I've reviewed some previous posts but haven't found the answer to my question.
Scenerio: Customer completes an application and we provide a GFE. The loan is then denied with a counteroffer.
Counteroffer is a different loan product so we have a changed circumstance and redisclose.
In a case like this, is the bank still bound by the fees on the original GFE unless the fees change BECAUSE of the new loan product (changed circumstance)?
Or are we starting all over as if we have a new application?
You sent a denial offering to consider them under different terms.
If they indicate they want to pursue the alternative terms then you have a changed circumstance and can issue a new GFE at that time with the applicable fees for the new terms. But until they indicate they want to apply for/accept the alternative terms you have no "changed circumstance" to issue a revised GFE. If they don't indicate they want to pursue the alternative terms then you need do nothing since you sent them the AAN giving the reasons you've denied the request as applied for.
Whether you treat is as a "new" application if they want to proceed would be decided by your application procedures.