Which of the following situations would require a new closing disclosure (CD) and a 3 business day delay?

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A new closing disclosure (CD) and a 3 business day delay are typically required when there are significant changes to the loan terms that could affect the borrower's decision to proceed with the mortgage transaction.

In the context of the given situation, a mortgage program change impacts the fundamental aspects of the loan itself. For instance, switching from a fixed-rate mortgage to an adjustable-rate mortgage or even changing from a conventional loan to a government-backed loan would alter the terms under which the borrower is receiving the funds. Such a change necessitates a new CD because it can significantly influence the cost structure, repayment terms, or potential risks associated with the mortgage.

While changes in interest rates, a borrower's employment status, and modifications to the loan term are important considerations, they do not automatically trigger the same level of disclosure requirements unless they result in a change to the terms that the borrower originally agreed to. For instance, changes in interest rates may not always lead to a new CD unless they exceed certain thresholds, and changes in employment may not directly impact the terms of the mortgage provided the borrower remains qualified. However, a shift in the mortgage program is clear-cut in its impact, leading to the necessity for a new CD and a waiting period.

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