I know there have a number of threads on change circumstances, but my question is - if there is no increase in fees and the change is only in the Summary of Loan information on the GFE page 1 - ie. loan amount, term, rate (and no impact to fees) - can a revised GFE be sent to the customer and not incur a violation? It seems unnecessary to me since the concern should be around increase fees not basic loan information - but I thought I would inquire.

What's the valid changed circumstance that would only affect the Summary of Loan information?

You canNOT do a revised GFE without a valid changed circumstance. Period.

I agree it doesn't sound like a VCC to me - but we've had occassions where the loan term changed and no impact to pricing/discounts - we've treated this as a "reissued GFE" rather than a VCC GFE to accomodate the customer and let them know the loan term info has been updated even though there was no impact to pricing. I'm having a difference of opinion with our compliance group who think this is acceptable. I think it is a VCC exception - do you agree?

Why not send a note confirming the changes and let the GFE alone, if all they want is acknowledgement from the bank?

I'm with TR and KB. Find another way to convey this information. It is not a valid CC and this is not the purpose of the GFE.

Why wouldn't a borrower-requested change of loan term, rate package, etc. be a CC under RESPA's definition:

Changed circumstances means:

(ii) Information particular to the borrower or transaction that was relied on in providing the GFE and that changes or is found to be inaccurate after the GFE has been provided. This may include information about the credit quality of the borrower, the amount of the loan, the estimated value of the property, or any other information that was used in providing the GFE;

(iii) New information particular to the borrower or transaction that was not relied on in providing the GFE;

and further under RESPA:

(3) Borrower-requested changes. If a borrower requests changes to the mortgage loan identified in the GFE that change the settlement charges or the terms of the loan, the loan originator may provide a revised GFE to the borrower. If a revised GFE is to be provided, the loan originator must do so within 3 business days of the borrower's request. The revised GFE may increase charges for services listed on the GFE only to the extent that the borrower-requested changes to the mortgage loan identified on the GFE actually resulted in higher charges.

Please see my post above.
I asked what the valid CC was.
The OP replied that they "treated this as a "reissued GFE" rather than a VCC GFE to accommodate the customer".
If they're relying on borrower request then there should be a documented valid CC in the file to support a redisclosure.
If it's not a borrower's request then again I ask, what's the valid CC that allows for the redisclosure?

Yes, a revised GFE may be provided if there are borrower-requested changes. This was not mentioned by the OP. However, if the fees didn't change, I wouldn't bother re-disclosing because it is not required.

I just assumed it was borrower requested. That's normally when we see it here.