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#1522378 - 03/16/11 02:04 PM REG Z - Modification
Whatup Offline
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Joined: Feb 2003
Posts: 379
Would the following scenario NOT be considered a refinancing under Reg Z and therefore not 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 and then revert back to P & I. We are not changing the term or the interest rate. Therefore, there will now be a balloon payment due at the end
Last edited by Whatup; 03/16/11 02:31 PM.
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Lending Compliance
#1523846 - 03/18/11 03:13 PM Re: REG Z - Modification Whatup
Whatup Offline
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Joined: Feb 2003
Posts: 379
Bump

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#1534656 - 04/12/11 08:34 PM Re: REG Z - Modification Whatup
West Coast Comp Offline
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West Coast Comp
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Posts: 350
Lost in the rain.
I would say no due to Sec. 226.20, since you are not replacing your obligation.
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#1534706 - 04/12/11 09:57 PM Re: REG Z - Modification West Coast Comp
Richard Insley Offline
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Richard Insley
Joined: Oct 2000
Posts: 10,181
Toano, VA
Originally Posted By: West Coast Comp
you are not replacing your obligation.
(...or adding a VR feature.)
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#1534717 - 04/12/11 10:38 PM Re: REG Z - Modification Richard Insley
West Coast Comp Offline
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West Coast Comp
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Posts: 350
Lost in the rain.
Good point Richard.
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