GFE

We received an application on 2/10 and prepared early disclosures. Customer called yesterday and wants to decrease loan amount by $12,000 - do we need to do a new GFE, and if so when does the time line start. As of 2/10/10 or as of 2/19/10??

What time start are you talking about? You're still offering the same rate, just changing the loan amount. You do a new GFE to change the amount and any other charges based on the loan amount. If that changes the APR, then you have to deal with MDIA and the three days there. Is that the time you meant?

A customer requested change is a qualified changed circumstance, if you choose to issue a revised GFE you must do so within 3 business days of learning of the changed circumstance, in this case 2/19/10 would be your start date.