Without the specific facts of each situation, we cannot give a specific answer to your question about obtaining a signature on redisclosed GFEs. We are not aware of any explicit legal requirement to have an applicant sign the GFE, though some investors may impose additional requirements on the loans they purchase. (Also note that an institution cannot charge any settlement service fees (for appraisals, inspections, etc.) until the loan applicant “has received the GFE and indicated an intention to proceed with the loan covered by the GFE.” 12 CFR 1024.7(a)(4).)

In some situations, the bank may benefit from having a signed copy of the redisclosed GFE. For example, if the changed circumstances result in a higher interest rate for the customer, an examiner may raise UDAAP concerns that might be mitigated if the redisclosed GFE was signed by the customer. And, if the bank has a policy requiring customers to sign or acknowledge receipt of the GFE, even if not required, it may be prudent to apply that policy consistently.