Loan Modification & New Disclosures Answer by Lucy Griffin, BOL Guru BIO AND CONTACT INFO
Question: Our institution offers a one close construction to permanent mortgage. The customer has the option to modify to a permanent financing program upon completion of the construction phase. We supply an advanced TIL upon closing the construction phase. Our modification does not replace the existing loan it simply changes the terms and the original mortgage stays in place. My question is: Are there any circumstances that would require us to provide new TIL, GFE, or any other disclosures prior to modifying the loan if we have properly completed those requirements at the time of the original construction closing?
Answer: As long as you are merely modifying an existing credit agreement and not issuing a new note, you have no new disclosure requirements. This is a case of "been there, done that."
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