At any time after you enter into a covered transaction, you must give immediate written notice to the Department of the Treasury office with which you entered into the transaction if you learn either that--
(a) You failed to disclose information earlier, as required by Sec. 19.335; or
(b) Due to changed circumstances, you or any of the principals for the transaction now meet any of the criteria in Sec. 19.335.
Disclosing Information--Lower Tier Participants