We redisclosed the GFE because the customer requested a new closing date, therefore, revised the pre-paid interest and the initial escrow deposit. Is this considered a changed circumstance?

Page 3 of the HUD was completed based on the revised GFE. is it okay to leave it as is since the daily interst and escrow are charges that can change or do we need to amend the HUD to reflect the charges from the initial HUD.

thanks,

If the customer made this request, but not because of an event the bank or settlement service provider had, then it's a changed circumstance.

My opinion: dates, odd days interest and escrows don't trigger a new GFE. The date info is in the terms and aren't a settlement fee issue. The odd interest and escrow are both unlimited tolerance, so it doesn't matter (to RESPA) if they are off.

You may want to inform your customer of these changes for customer service reasons, but it's not necessary for RESPA.

Follow-up question - if the loan closes on the 1st of the month such that the odd days interest (line #901) is $0, on page 3 comparison do you put an amount for the GFE column or do you treat it like owner's title, VOE fees, etc? I know it really has no impact as the odd days interest is in the unlimited increase category but I'm wondering what would be correct.

Thanks!