Under §1026.19(e)(3)(iv)(A), a changed circumstance affecting settlement charges can include, per paragraph (2), "Information specific to the consumer or transaction that the creditor relied upon when providing the disclosures required under paragraph (e)(1)(i) of this section and that was inaccurate or changed after the disclosures were provided."
The consumer's request that the dollar amount of the loan be increased is not one of the examples provided in the commentary to this section; however, it would most certainly be "information specific to the...transaction that the creditor relied upon when providing the [initial loan estimate] and that was inaccurate or changed after the disclosures were provided." If the origination fee is a percentage of the loan amount, it would be directly affected by the increased loan amount, and, assuming a timely revised loan estimate is issued with that increase, I see absolutely no reason it would not fit the wording of the regulation exactly.
Reread the guidance from WK and Encompass to see if there are specifics cited that would justify such guidance. Absent such specifics, I'd question the accuracy of those guidance documents.
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8