If a loan has a rate lock at an initially lower rate, was extended, but at a higher rate, then not disclosed to the borrower would we be in violation of 19(e)(3)(iv)(D) for not disclosing the higher rate amount to the borrower? Further more, if when we extended the lock there wasn't a charge, but now there is due to another extension could we pass the fee along to the borrower if it was within three days?
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