Q: Would the discovery of additional documents (such as releases) that must be recorded causing an increase in government recording fees be considered a "changed circumstance" allowing the loan originator to provide a revised GFE?

A: The discovery of previously undisclosed circumstances affecting settlement costs such as unreleased liens could be considered a "changed circumstance." A loan originator may choose to issue a revised GFE reflecting only the increased charges resulting from the "changed circumstance" or may choose not to reissue a GFE if the increase is minimal. If the loan originator chooses to issue a revised GFE, only the increase in recording fees may change on the GFE: all other charges must remain the same.

This can be found in GFE-Changed Circumstances – FAQ #2 of HUD’s FAQs.  HUD’s FAQs can be found at http://www.hud.gov/offices/hsg/rmra/res/respa_hm.cfm.