I agree with Skittles. A reduced rate (and APR) in and of itself typically does not trigger a new LE. That said, if the rate was previously floating but now locked, a new LE would be required.
You have probably already thought of this, but if you have lowered your rate to keep a customer, you will want to make a good note of it for fair lending purposes (as well as review the impact of the practice on your fair lending posture).
Adam Witmer, CRCM
All statements are my opinion, not those of my employer, and should not be taken as legal advice.www.compliancecohort.com