At the time of early disclosures we do not know who the borrower is going to choose and we put a title company and provide a WSSPL. At the point of a changed circumstance the borrower gives information they will use a particular company, Under TRID 2.0 do we have to update the revised disclosures to the company the borrower is actually going to use?

If you know the charges are going to be different - yes you do. Do you have to go out of the way to make that determination - not really.

Only if it's information made apparent, i.e. a settlement statement from the Title company, then we'd be obligated to update, correct? Otherwise if we don't have a statement, but just know they're not going to use the company listed on the WSSPL then we would still be within compliance by keeping the fees on the revised loan estimate the same?

I am not aware that there is a requirement to get specifically on the horn and call them to get updated figures. I guess it comes down to what you feel is reasonably available.

Good faith goes back to 1026.17(c)(2)(i) If any information necessary for an accurate disclosure is unknown to the creditor, the creditor shall make the disclosure based on the best information reasonably available at the time the disclosure is provided to the consumer, and shall state clearly that the disclosure is an estimate.

That helps a lot! As always, you've been extremely helpful!