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Under RESPA’s changed circumstance, it referes to a borrower requested change that “change the settlement charges or the terms of the loan.” Would a change in the interest rate and/or the number of payments be considered changing the terms of the note? After issuing a GFE, our borrower requested the term of the note be extended and the interest rate be lowered. With the change in interest rate, this would affect the APR along with other calculations. However, would either of these (rate and term) individually or collectively be a change in circumstance? I have read through the Q & A, but I can’t seem to get a good comfort level. Thanks for your help.
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