If my customer had originally locked a loan at 30 years, and changed to a 20 year loan, same dollar amount, same rate, no fees changed--there is no requirement to issue a revised LE correct? We would just show the changed term on the CD.

Loan term change alone is not a changed circumstance if it does not impact any fees subject to your tolerance tests.

Would it make a difference if there was a new rate lock for the 20 year?

Only an initial rate lock is required to be disclosed under 19(e)(3)(iv)(D) even if there is no change in fees. Subsequent rate locks would be a changed circumstance if it impacted interest rate dependent fees. If these are secondary market loan, your investor may have additional requirements.

Thank you Randy.