We have a borrower who is experiencing temporary financial difficulties, he has a residential mortgage loan with us. We have agreed to reduce his rate and payment for 6 months to help him catch up. Based on what I read 1026.20c then we can do this and do not need to provide any new disclosures. My questions:
1. when we change the rate back to the note rate in 6 months will disclosures be necessary?
2. If we do a property evaluation and want to charge the borrower for this, will disclosures be required. ( fee is under $150)
Your help is appreciated.