If you are issuing a disclosure, whether an initial or subsequent disclosure, those disclosure are provided under .19(e)(1)(i) and all subsequent disclosure would be considered under the general good faith provisions and all such charges would have to be disclosed at that time. Failure to do so, IMHO, is going to require a cure.
19(e)(3)(iii) Variations permitted for certain charges.
Comment 3 - For example, if the consumer informs the creditor that the consumer will obtain a type of inspection not required by the creditor, the creditor must include the charge for that item in the disclosures provided under § 1026.19(e)(1)(i), but the actual amount of the inspection fee need not be compared to the original estimate for the inspection fee to perform the good faith analysis required by § 1026.19(e)(3)(iii). The original estimated charge, or lack of an estimated charge for a particular service, complies with § 1026.19(e)(3)(iii) if it is made based on the best information reasonably available to the creditor at the time that the estimate was provided.
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