OK - - -RESPA novice here - - can I get some of you Pros to help me out with two things I am seeing on our files?

1. GFE issued. A few days later, GFE re-disclosed with no changes. It looks EXACTLY the same as the first GFE other than the "date of GFE" field. No rate lock, No change in circumstances. I can't figure it out. Any ideas?

2. Same situation as above, except we are changing the credit bureau fee on the 2nd. The first GFE has the estimated cost that comes right off of the software. The redisclosure has the actual cost. My understanding is that we can't re-issue to change fee. The argument is that we are giving them the exact cost on the second. Can't that box change at closing? We're talking about a redisclosure for less than a buck. I'm seeing it as a non-permissible reissue.

Beginning to be sorry I "expanded scope" and looked at these. Thanks for help.

1) You need to go to the LO and/or processor and get them to explain why they redisclosed. Even if it just went from floating to locked, the dates should have changed. Otherwise, no clue.

2) There is no argument to be made here. RESPA is very clear. A change in fees is NOT a changed circumstance. Period. It doesn't matter if you think you're giving the borrower exact costs. It's called a Good Faith ESTIMATE not a good faith exact.

I love your answer to number 2, TR. I am forwarding to my LO on this one. Our compliance officer says no; it's gotta be exact. Hopefully, he's out here reading now!

Make your compliance officer show you where in RESPA or any training they got that it says it's gotta be exact.
Can't be done because it doesn't exist.

Glad I could make you smile in spite of your expanded scope.