So, do banks normally modify mortgage loans. For example: cusotmer comes into the bank and requests an additonal $10,000. They have no additional collateral to offer. The home securing their current home mortgage has sufficient equity.
Our procedures are to take a new residential application, new disclosures, everything - and do a new note. Seems very inefficient...but that's what we do.
If we do the modification and include a TIL for the new terms, amounts, etc., and a ROR for the new money...are we in compliance? Is there something more to this? I am being challenged to find a better solution to the process for modificaitons when someone requests new money on their existing debt.