We provided a Loan Estimate detailing a fixed rate loan. The applicant is now asking for an ARM. We would provide our early ARM disclosure and the CHARM booklet. No fees are changing - so a revised Loan Estimate is not required. Correct? We will show the product change on our Closing Disclosure. I understand we can provide a revised LE for informational purposes only but want to make sure it is not required since a lot of the detail on the LE will no longer be accurate.) Thank you.

Correct on all accounts.

You're changing the loan program and have to issue them the CHARM booklet, you might as well disclose a new LE with the ARM tables. You obviously wouldn't issue a fixed LE.