Some of the loan files I review for RESPA lack good evidence of the changed circumstance that led to a redisclosure of the GFE. While I can generally figure it out, I was wondering if any of you have implemented procedures to better document a changed circumstance requiring redisclosure. I have come across files where there were multiple re-disclosures. Its hard to follow. They all look legit after I figure out what happened but I think a document on the inside cover stating why the change occured would be helpful. Any comments or even forms would be appreciated.

Thanks

We have a flow sheet and on this sheet it is documented when the specific disclosure was provided and if it was mailed or provided in person. There is a "sub-line" titled Redisclosure which is to be completed with the date and how it was provided and why it was provided.

I've seen two different versions of forms.
The one I prefer has one CC to a page.
Borrower name:
Loan number:
Date of CC
A revised GFE is being issued due to the following changed circumstance:
___Borrower intiated request
___Rate intially floating and now locking
___Borrower intiated relock or extension with increased fee for extension
___new information unknown to originator at time of original GFE
___Other
Describe circumstance:

Estimates for the folloiwng charges are being revised:
Line # Description of fee previous estimate revised estimate

Another form I've seen has blocks for multiple CCs all on the same page. I don't care for it as much so I'm not coying it here. I like the first form because I can put it in front of the revised GFE in the file. Keeps all the info together.

We require a note to the 'notepad' of our LOS describing why they are issuing a GFE.

Our new LOS that we are going to actually requires the LO/processor to write a reason why a new GFE is being created before the system allows the new GFE to be generated.

That is a feature I am looking forward to.

Good info. Thanks Guys!

We currently have this process.

Jay, I am wondering what is the name of your new software? I like the sound of that function.

I'll PM you.