If we issue an Early HELOC Disclosure with a fee for an appraisal and find out later that another appraisal may be warranted with an additional fee, are we within the definition of "issued in good faith" on the initial disclosure or should we redisclose to the consumer with the extra appraisal fee?

I am not sure that would trigger a new early disclosure. There are no specific tolerance tests in 1026.40 and as long as it was in good faith when it was issued, I think it complies.

I am not sure what circumstance would warrant another appraisal that the borrower would be forced to pay for however.