In the RESPA FAQ’s page 24 #12 it states that that in the important dates section line #2 stays the same date from the initial GFE to the revised GFE if the intent to proceed has happened. We have not done this properly and when looking at the dates of the revised GFE, date #2 we have given them an additional 10 business days based on the date of the revised GFE and not kept the date the same from the initial GFE. Is it a violation of RESPA to have those extra 10 business days on line #2 on the revised GFE?
Line 2 of revised GFE should be the same as it was on the original GFE. I don’t believe you have much to worry about since you have been giving the customer more benefit (assuming you have honored the extra 10 days).