We have an applicant that originally applied for a bridge loan. They have signed their intent to proceed and we have completed appraisals and flood determinations on both properties. Before we closed the bridge loan they sold their house and now want to have a purchase money only.

I assume that we can collect the fees since they signed their intent to proceed from the bridge application. Can we show the original loan application as being withdrawn and start over? If we do are we required to get a new application? How will we show the appraisal fee since we are not going to charge them for it again?

I would simply document the change in circumstances. In my mind, all I see really changing is the term, so I would not re-disclose for that alone.

If you start from scratch, you will follow the 'service used in prior transaction' rules from the roundup letters.

I see no need to start over either.

I have a little more info to add.

Since we are no longer completing a bridge loan we will have a new loan amount, rate and length of repayment.

If we change those items mentioned above, how are we to disclose the appraisals and flood searches used for the bridge loan? Can we just show all of the fees that the borrower is responsible for?

If it were me...I would make the necessary changes to the applicantion and have it dated and initialed.

If the changes caused changes to my initial disclosures, I would completed a COC and then re-issue the GFE if fees increased. Otherwise, I would continue on with my original GFE.

Be sure you re-work your eTIL, however, in the event your APR changes and is out of tolerance.