While reviewing the HMDA LAR information on a loan, I discovered that one of our loans was set up as a business loan. It is truly a consumer refinance (we added parents to the son's loan for strength). Problem is that no consumer disclosures went out and no right of rescission was done. Short of paying this loan off and correctly "re-doing" the loan, I was curious if there is anything that can be done to correct this mistake?? Any suggestions would be appreciated.

Short of paying this loan off and correctly "re-doing" the loan.

This doesn't negate your violations or financial liability.

RESPA - You will need to properly complete the HUD. On page 3 in the comparison chart you will enter $0.00 in the GFE column and the actual charge in the HUD column and make the necessary cure to the borrower.

Reg Z.

ROR - not anything you can do. They have 3 years to rescind if the refinancing was subject to rescission.

TIL - you will use the contract rate as the APR. The following document will give you guidance on any reimbursement requirements.

http://www.fdic.gov/regulations/laws/rules/5000-300.html