What are the early disclosures required (within 3 business days) on a closed-end loan (2nd lien) refinance of investment property?
My answer was none, but wanted to make sure. In this case, since the loan is being written as a home equity loan and not a busines loan, we were going to send a GFE and TIL just so they understand what the costs will be, etc.
Is this an appropriate way to handle it?