Well, if you are going to post an example, make it correct. Because unlike most people, compliance officers are a stickler for details and if the details do not make sense, then you are not going to get anyone to opine.
If you want a well thought out answer, post a well thought out question.
Unless you were previously billing your annual fee in arrears and you are now going to bill your annual fee in advance, this process makes absolutely no sense at all. You would be double dipping as the borrower already paid their annual fee up to the next due date and that would be a UDAAP issue.
Whether you can do this or not is a matter of State law, but I surely hope this was all fully explained in the change of terms notice otherwise it would appear to me to present some UDAAP issues.
Welcome to BOL