Skip to content
BOL Conferences
Thread Options
#1524467 - 03/21/11 03:14 PM REG Z - Refinance?
Whatup Offline
Gold Star
Joined: Feb 2003
Posts: 379
Would the following scenario be considered a refinancing under Reg Z and therefore require re-disclosure?

*Mobile Home NO land - principal dwelling
The current loan is a fixed rate fully amortizing loan for 15 years. We are modifying the loan to allow for 6 months interest only, while they try to sell and then revert back to P & I after 6 months if the home has not sold. We are not changing the original term or the interest rate. Therefore, there will now be a balloon payment due at the end of the loan

Return to Top
Lending Compliance
#1524493 - 03/21/11 03:41 PM Re: REG Z - Refinance? Whatup
Richard Insley Offline
10K Club
Richard Insley
Joined: Oct 2000
Posts: 10,179
Toano, VA
Originally Posted By: Whatup
We are modifying...

You could have stopped right here. Unless you're canceling & replacing then old note with a new one, it's not a refinance requiring new disclosures. The only exception would be the addition of a VR feature--which you are not doing.
_________________________
...gone fishing.

Return to Top
#1524496 - 03/21/11 03:42 PM Re: REG Z - Refinance? Richard Insley
Whatup Offline
Gold Star
Joined: Feb 2003
Posts: 379
Thank you

Return to Top

Moderator:  Andy_Z