I agree with you that a changed circumstance could include - "(3) New information particular to the borrower or transaction that was not relied on in providing the GFE;"
However, as a follow-up, unless the application was taken on-line, how could someone apply for a loan and "forget" to mention that the property was on the water? If the app was taken by a LO, the LO was not doing their job at all because they need to know all about the transaction to make sure it is properly looked at. If it were mentioned to the LO, and the LO did not write it down, then, IMHO, there is no changed circumstance.
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Integrity. With it, nothing else matters. Without it, nothing else matters.