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#1670785 - 02/28/12 08:15 PM Redisclosure Required??
Ninky Offline
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Ninky
Joined: Nov 2002
Posts: 357
WE have a 12 month temporary purchase money, prin dwelling that is about to mature. Borrow has requested a renewal to extend for 6 months. No new note. We will continue the variable rate payment structure; however, we want to go from interest only to a P&I payment. I know variable to variable is not redisclosable, does the same apply here? It is the same rate variable to variable, but the payment will increase to include a principal portion in the payment. Do we have to re-disclose?

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Lending Compliance
#1670804 - 02/28/12 08:44 PM Re: Redisclosure Required?? Ninky
Richard Insley Online
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Richard Insley
Joined: Oct 2000
Posts: 10,179
Toano, VA
If you aren't replacing the old note and the VR provision is unchanged, nothing else could cause your changes to become a "refinancing" under Section 20(a) of Reg. Z.
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