Changed Circumstance or Other Triggering Event (TILA-RESPA)

Updated 2026-05-17

A changed circumstance or other triggering event is a specific condition that allows a creditor to revise a previously issued Loan Estimate or (where still used) Good Faith Estimate without violating fee Tolerances (Loan Costs), if the revised disclosure is issued on time. Under TRID, initial Loan Estimate fees and terms generally cannot increase beyond tolerance limits unless a permitted event occurs and a revised estimate is provided within three business days of receiving sufficient information.

Under the 2018 TILA RESPA Rule (TRID), this is crucial because, generally, the fees and terms disclosed on the initial Loan Estimate are subject to tolerances and cannot increase beyond certain limits.

General Principles for Changed Circumstances

A changed circumstance must be one of the following:

1. Extraordinary event: An act of God, war, disaster, or other emergency.
2. Information specific to the consumer or transaction: Information relied upon in providing the original disclosures that was inaccurate or changed, and was not known or could not have been reasonably discovered by the creditor at the time the disclosures were provided.
3. New information: New information regarding the consumer or transaction that the creditor did not rely on when providing the original disclosures.
4. Borrower request: A request by the consumer for a change to the loan terms or settlement services.
5. Expiration of the original disclosure: If the consumer does not indicate an intent to proceed within 10 business days of the disclosure being provided, the creditor may issue a revised disclosure.
6. Interest rate lock: If the interest rate was not locked when the original disclosure was provided, and the consumer subsequently locks the rate, or if a locked rate expires.

For Good Faith Estimates (GFE)

For the Good Faith Estimate (GFE), which is primarily used for reverse mortgage applications, 12 CFR § 1024.7 outlines specific changed circumstances that permit a revised GFE:

• Changed circumstances affecting settlement costs: An unexpected event that increases the cost of settlement services.
• Changed circumstances affecting the borrower's eligibility: New information that affects the borrower's creditworthiness or the value of the property.
• Borrower-requested changes: When the borrower requests a change to the loan terms or settlement services.
• Expiration of the GFE: If the borrower does not express an intent to proceed with the loan within 10 business days, the GFE expires.
• Interest rate-dependent charges: If the interest rate was not locked and it changes.

In the event of a legitimate changed circumstance, the lender must provide a revised GFE within three business days of receiving the new information.

For Loan Estimates (LE)

For the Loan Estimate (LE), used for most other mortgage transactions under the TRID Rule, similar principles apply, as detailed in Regulation Z (12 CFR Part 1026). A revised Loan Estimate may be issued due to:

• Changed circumstances: Events that affect the settlement costs or the borrower's eligibility.
• Borrower-requested changes: Alterations to the loan or services requested by the consumer.
• Interest rate lock: If the interest rate is locked after the initial LE, or if the rate expires.
• Consumer's intent to proceed: If the consumer indicates intent to proceed more than 10 business days after the LE was provided.
• New construction loans: Delays in new construction where the original LE was provided without a specific property.

Common Scenarios Leading to a Revised Loan Estimate

Specific examples of events that qualify as a changed circumstance and may lead to a revised Loan Estimate include:

• A change in loan programs requested by the borrower.
• A decision by the borrower to make a lower down payment.
• An The Appraisal Foundation value significantly different (lower or higher) from the initial estimate, impacting the loan-to-value ratio or requiring mortgage insurance.
• A drop in the borrower's VA-Approved Credit Underwriter and Underwriting Standards (e.g., due to new debt or missed payments).
• Inability to document income initially included in the application.

For most changed circumstances affecting the Loan Estimate, a revised disclosure must be provided within three business days of the creditor receiving information sufficient to establish that a changed circumstance has occurred.

What MLOs must know for the SAFE exam

• Qualifying events include extraordinary events, inaccurate/changed information relied on, new information, borrower-requested changes, expiration after 10 business days without intent to proceed, and interest-rate lock events.
• Common LE revision scenarios: loan program change, lower down payment, appraisal value shift, credit deterioration, and inability to document income.
• A revised Loan Estimate for most changed circumstances must be provided within three business days of receiving information sufficient to establish the event.
• GFE changed-circumstance rules (Reg X § 1024.7) still matter mainly for reverse mortgages and other non-TRID transactions.
• Without a valid changed circumstance (or other trigger) and timely redisclosure, fee increases may violate tolerances.

Citations

• 12 CFR § 1024.7 (Reg X)
• 12 CFR § 1026.19(e)(3)(iv) (Reg Z)