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#120811 - 10/07/03 05:57 PM RESPA- Purchase money seconds
Ninky Offline
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Ninky
Joined: Nov 2002
Posts: 357
If you are making a purchase money second, but are not the lender for the 1st mortgage, are the Special Information Booklet and mortgage servicing disclosure statement required disclosures?

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Lending Compliance
#120812 - 10/07/03 06:21 PM Re: RESPA- Purchase money seconds
Deena Offline
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Deena
Joined: Nov 2000
Posts: 2,701
PA
I would say yes for the booklet because it's a purchase transaction, but I would say no for the Servicing Transfer Disclosure since it's not a first lien.
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Opinions expressed are mine and not necessarily those of my employer.

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#120813 - 10/07/03 06:45 PM Re: RESPA- Purchase money seconds
Ninky Offline
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Ninky
Joined: Nov 2002
Posts: 357
Since it is a 2nd lien transaction, no early TIL, right?

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#120814 - 10/07/03 07:48 PM Re: RESPA- Purchase money seconds
Deena Offline
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Deena
Joined: Nov 2000
Posts: 2,701
PA
You do need an early TIL - see 226.19(a)
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Opinions expressed are mine and not necessarily those of my employer.

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#120815 - 10/08/03 03:24 AM Re: RESPA- Purchase money seconds
David Dickinson Offline
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David Dickinson
Joined: Nov 2000
Posts: 18,763
Central City, NE
Just because this is a subordinate lien, doesn't mean anything is exempt (other than the Servicing Disclosure - which some are not even providing now). Treat just like any other purchase loan (HUD-1, P-TIL, etc.).
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David Dickinson
http://www.bankerscompliance.com

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