Skip to content
BOL Conferences
Thread Options
#1660726 - 02/03/12 10:03 PM Disclosures required?
CMLComp Offline
Member
Joined: Dec 2011
Posts: 90
Banker renewing unsecured consumer loan, no credit report pulled. Any disclosures required? Only change outside of extending maturity date is to correct the interest calculation method from 365/360 to 365/365 (documented incorrectly previously). From a systems perspective we can doc that via Change in Terms versus Promissory Note, any issues with that?

Return to Top
Lending Compliance
#1660753 - 02/03/12 10:43 PM Re: Disclosures required? CMLComp
Andy_Z Offline
10K Club
Andy_Z
Joined: Oct 2000
Posts: 27,746
On the Net
Based on 1026.20 I think you're fine assuming you modify and don't replace the note. The accrual method throws me off though. It was originally contracted at 365/360 and will now be actual? Depending on the dollars involved seems minor, but I'm unsure.
_________________________
AndyZ CRCM
My opinions are not necessarily my employers.
R+R-R=R+R
Rules and Regs minus Relationships equals Resentment and Rebellion. John Maxwell

Return to Top
#1660859 - 02/06/12 01:32 PM Re: Disclosures required? CMLComp
CMLComp Offline
Member
Joined: Dec 2011
Posts: 90
I've asked the lender to confirm whether changing the rate calculation will decrease the customer's rate or otherwise favorably change their terms. Even if it qualifies as a refinance if the APR is being increased, a final TIL wouldn't be required unless it's under $51,800, correct?

Return to Top

Moderator:  Andy_Z