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Lowering Interest Rates on Existing Mortgages
Answer by Richard Insley, BOL Guru
Guru Bio
Question: We are offering to lower the interest rates on existing mortgage loans for our good customers. Do we need a new disclosure signed by the customer?
Answer: If the rate reduction is accomplished by refinancing the original loan (as defined in Section 226.20(a) of Reg Z), then new TIL disclosures are required. Reg Z never requires you to obtain a borrowers signature acknowledging receipt of required disclosures.
First published on BankersOnline.com 4/14/08

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