I couldn't find anything in these threads that mention this situation. We left the name of a couple of the item descriptions for fees charged on the Loan Estimate. From what I'm reading, including the CFPB's Small Entity Guide, although we are required to "label the loan costs disclosed pursuant §1026.37(f) using terminology that describes each item" it does not appear to fall into any of the reasons for having to provide a revised estimate. Apparently our LOS is saying that we're in violation of the rule if we don't name the costs and is requiring us to issue a revised estimate. Thoughts?

I'm not fully understanding the issue.
Did you just put fees with no name on the LE?
That would be a technical violation.

Then we get to 'your LOS is requiring you...?'
You redisclose when you have a valid CC that allows you to.
A bank error, even in fee naming, is not a valid CC.
Note the file and move on.
If you have a valid CC in the future, put the names on so they match on the CD.

Thank you Truffle. And I apologize for not being clear. However, you fully understood me because you answered my question. I agree, leaving the name of the fee off the LE is a technical error that does not require us to issue a revised LE just to add the name. However, our system "says" that a revised LE is required under this circumstance for whatever reason and I needed reassurance that I was reading the regulation correctly.
Thank you again for your input! It's greatly appreciated.

Glad I could help.

On a related question, had ItsJustMe issued a revised LE in this scenario (and as concluded is not a valid CC), is this allowed?

In other words, if you find other technical errors (that are not CCs), is it an actual violation to issue a revised LE to provide the consumer the best possible and accurate LE?

Actually, any time you issue a LE or CD it has to be based on all knowledge and good faith of the lender at the time of issuance.

No, it would not be a violation to issue a new LE, but you would need to make sure such a disclosure was not used to reset tolerance standards. It would be similar to providing an "informational" LE.

Thanks, that's what I thought. My problem is, my auditor and I are having this debate and I can't seem to find it in the reg or commentary regarding revised LEs (that's not a CC). Auditor is relying on the base reg wording that says "generally no revisions may be issued due to technical errors, etc".

Can anyone kindly help me find or prove I can reissue the LE when a CC is not the reason?

You might want to tell the auditor to sit down and read the new TRID amendments:

"As finalized, comments 19(e)(3)(iv)-2 and -4 are consistent with current comment 19(e)(3)(iv)(A)-1.ii, which states that § 1026.19(e)(3)(iv) does not prohibit the creditor from issuing revised disclosures for informational purposes, even in situations where the creditor is not resetting tolerances for any of the reasons stated in § 1026.19(e)(3)(iv)(A) through (F)."

and

"The Bureau concludes that the concerns expressed by consumer group commenters do not warrant prohibiting consumers from receiving the best information reasonably available, even if consumers will later receive a Closing Disclosure. Regarding commenters’ assertion that consumers will not understand the difference between revised Loan Estimates for resetting tolerances and those simply for informational purposes, the Bureau notes that the Loan Estimate form intentionally has been designed, first and foremost, as a means of providing consumers with the best information reasonably available."

Thank you so much!