For our portfolio mortgage loans, we do not charge Late Charges. But if we sell a loan to a correspondent, the correspondent will require late charges. If we issue our Loan Estimate with no late charges, but then the loan switches to being a correspondent loan (for various reasons), can we add Late Charges at CD? This is not a changed circumstance so we would not issue a revised LE because there are no tolerances to reset. But, I'm wondering if we are locked in to the no late charges that we initially disclosed?

If it worries you, why not go in the other direction. Disclose it on the LE and then not on the CD for portfolio loans. Hard to say whether a regulator might find adding a late charge later is a UDAAP.

Thank you - good idea.