What disclosures would be required when modifying an open end HELOC to a closed end bi-weekly mortgage? Our loan department just did one and all they prepared was a modification agreement.

Assuming they modified from a variable rate to a fixed rate, none. If they modified from a variable to a variable then you need to look at the OSC to 226.20(a)(3).

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Our loan department just did one and all they prepared was a modification agreement.

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I think in many states it would also require a new deed of trust to be filed.

I have to also disagree with Dan, as this was originally subject to Subpart B and thus would not be eligible under the exemptions from refinancing under 226.20.

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I have to also disagree with Dan, as this was originally subject to Subpart B and thus would not be eligible under the exemptions from refinancing under 226.20.

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Ooops! It did say HELOC didnt' it.

Okay, I am the original poster. To clarify, the modification WOULD require all new disclosures (as if it were a refinance)??? As you know, they are modifying an open end line and "changing" it to a closed end mortgage.

Please help!

I believe that it would.