I can argue in different directions on this, but haven't found anything definitive.

We have a HELOC application that was taken under a No Closing Costs plan; the application disclosure lists that there are no third-party fees.

However, the decision by a loan committee is that we are to split the loan fees with the customer. There is no origination fee and no prepaid interest, so there should not be a change to the APR.

If this was a closed-end homequity application, we might have a case of a changed circumstance (depending on the reason for our decision, which is a whole different issue), and we would be required to re-issue the GFE within 3 days of the changed circumstance, but with no waiting before closing. Would the same thing apply here? Just give the customer a new application disclosure showing the expected third-party fees, and go ahead and close?

Surely someone else has run into this.

Just because you have a valid changed circumstances does NOT mean you are required to re-issue the GFE.

That said, I'm thinking you're going to have to do something to communicate the fact that you're not paying as promised now. I don't think how you do it is mandated by a Reg.