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Lowering Rates on Existing Mortgages - Redisclose
Answer by Dan Persfull and Richard Insley, BOL Gurus
Guru Bio
Question: Due to the current rate environment, we have decided to lower some rates on existing mortgages. We are charging a flat fee of $200 and completing a change in terms agreement to show the new payment terms. Do we have to redisclose the APR and fee since we are changing the terms to benefit the consumer?
Answer by Dan Persfull: Modifications do not require redisclosures.
Answer by Richard Insley: Modifications that add a variable rate feature do require redisclosures.
First published on BankersOnline.com 4/28/08
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