The only reference I saw sort of to this point was in a webinar where it was stated that just because you had one of the six pieces of information that make a TRID completed application from a prior transaction does not mean you have a completed application for the current transaction. In other words, just because you had their income from a prior loan application doesn't mean you have it for the current app.
With regard to knowing that the property is a MH and there would be a fee, if you knew that from a prior transaction, I think you'd be hard pressed to say learning of the fee was a change in circumstance. I tend to agree with the processors and say you reasonably should have known this at the time of initial disclosure.
Jim Bedsole, CRCM, CBA, CFSA, CAFP
My posts - my opinions