Coworkers and I are in dispute again

On our 1st mortgage files we have always done an estimated GFE at the time of application and then a Final GFE at closing.

I have always been under then impression that a final GFE is not required. The problem we have now is that when title, attorney fees, overnight fees, etc change at closing that our final GFE does not match the HUD which our auditor then brings up that they should match if we are doing a Final GFE.

Do we need them? Can you direct me to the paragaph stating the answer? Thank you!

The Good Faith Estimate is just that an estimate. See 3500.7(c)(2). You shouldn't need a final GFE unless some of the charges changed drastically. When I used to audit these I looked for a difference of more than $500 in total charges. This may not necessarily be the correct figure - there is no definition of reasonable.

I'll even argue you never need a new GFE - even if it changes 1000% as long as you don't have a new application. The GFE is an estimate (as WW said). The Settlement Statement is the final/actual.