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).
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Adam Witmer, CRCM
All statements are my opinion, not those of my employer, and should not be taken as legal advice.
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