We sent a revised PTIL when the customer locked their rate. At this time, we also discovered that the govt recording chgs were going to be 200.00 instead of the 41.00 we listed on the initial PTIL. Therefore on the revised PTIL we listed 200.00 for the govt recording chgs.

Should the revised PTIL still list 41.00 as this fee was not affected by the specific changed circumstance?

Was there a valid changed circumstance behind the jump in recording fees? If so, you could have redisclosed for both the lock and the fee increase on the same GFE as long as you documented the file properly.

If you just misquoted the fee with no valid CC behind it then you're stuck with the $41 and curing if need be.

Yes, there was a valid changed circumstance behind the jump in recording fees - it wasn't a misquote.

I think what we're missing is just proper documentation in the file then - thanks.

What terms of the loan changed to cause the recording fees to jump from $41 to $200?

The loan officer told me they were notified of the increase. I'm not sure what the specific reason was.

I think you're missing my point, morise. Being notified of the increase does NOT make it a valid changed circumstance. Something that is a valid changed circumstance had to happen to warrant the increase. An example might be if you found out after the first GFE was delivered that some document that you wouldn't have in a 'normal' closing was required to transfer the title properly. That would be a changed circumstance that would allow the fee to increase.

But Dan's right to question the fee more than quadrupling like that. That's highly unusual. Wo what reason did the LO give for the fee increase?

Then you need to do some more due diligence. As TR stated above there has to be a qualified changed circumstance. And pardon my language but there would have to be one [censored] of a changed circumstance to cause the recording fees to jump from $41 to $200. (At $2.50 per page that would equate to an additional 63.6 pages to be recorded. What on earth would require that many pages to be recorded). If they forgot to quote a tax stamp or something similar then that's just a screw up and not a changed circumstance.

This loan was out of state. We looked up the recording fees online to see what they would be. The customer used a settlement agent and the bill from them for the recording fee was 200.00. The lender says he does not know why it was so much.
I'm not familiar with how this works - maybe some of this fee is for the settlement agent?
So would this not be a changed circumstance since we didn't get the fee right in the first place?

As Dan pointed out, you'll need to find out why the increase occurred. If it was simply "we didn't know the price in that area" (out of state), that's not a changed circumstance.

If you looked up the recording fee on the Recorder's website and then got socked with a bill for $200 from the settlement agent, I'd be calling that agent and finding out what the other $169 was for. If it's settlement agent fees, you need to do a new HUD and split out that part and rework your tolerances accordingly.