We are re-disclosing "informational" LE's to our borrowers regardless of CC or not
You mean it doesn't matter what the CC is not that you don't have one, right? Because you still can't redisclose without a valid changed circumstance.
Additionally, you have to be aware of resetting tolerance baselines properly.
Personally, I think papering the borrower with LEs doesn't help them, it only confuses them.