Thread Options
#1806502 - 04/19/13 04:40 PM Consumer Loan Modification
Funky Falcon Offline
100 Club
Joined: Jan 2008
Posts: 242
Minnesota
If we're modifying a consumer loan by extending the maturity date, adding a voluntary escrow (it's a mobile home loan), therefore changing the payment - would we have to redisclose a new Truth in Lending disclosure to the customer?

It techinically doesn't meet the definition of a refi, so my gut is telling me no...

Return to Top
Lending Compliance
#1806507 - 04/19/13 04:48 PM Re: Consumer Loan Modification Funky Falcon
Richard Insley Offline
10K Club
Richard Insley
Joined: Oct 2000
Posts: 10,049
Toano, VA
Unless you are satisfying the old note and replacing it with a new one (or adding a variable rate feature), no.
_________________________
...gone fishing.

Return to Top

Moderator:  Andy_Z