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#176405 - 04/02/04 06:13 PM TIL Redisclosure Closed End
inquiringmind Offline
100 Club
Joined: Mar 2003
Posts: 155
The bank merged with another bank that offered a weird ARM. To get these loans to conform with our loans, we propose to offer a loan modification whereby we would reduce the APR and modify the ARM to a fixed rate and change the due date to the first of the month and change the grace period (from 30 days to 15). Would such a modification require redisclosure? Please provide TIL citation if possible. Thanks

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Lending Compliance
#176406 - 04/02/04 06:51 PM Re: TIL Redisclosure Closed End
Dan Persfull Offline
10K Club
Dan Persfull
Joined: Aug 2002
Posts: 47,517
Bloomington, IN
226.20 and its commentary.

Modifying from an ARM to a fixed rate product does not constitute a refinancing and new TIL disclosures are not required.
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The opinions expressed are mine and they are not to be taken as legal advice.

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