After disclosures were sent out on a fixed rate mortgage loan, the customer decided they would like to escrow. Are we required to send a GFE with the preliminary disclosure or is the preliminary disclosure sufficient?

I would think that you would want your GFE to match what you are actually doing.

I too would advise our lending staff to include a revised GFE. If the borrowers are asking to now include escrow you surely have a changed circumstance (borrower requested change affecting the loan) and therefore you should re-disclose.

RESPA only requires re-disclosure when you lock the loan.

RESPA says you "may" redisclose for other types of valid Changed Circumstances...of course you would prudently decide to re-disclose if it was an increased fee that might affect your tolerances negatively BUT the good news is that areas not subject to a tolerance, like escrow, don't need to be re-disclosed.

We have decided not to re-disclose unless "required" as each re-disclosure is an opportunity for a mistake.