We have an existing line of credit which only holds an annuity as collateral. We now want to add the borrower's secondary residence to the loan. I am not finding information in RESPA that any disclosures need to be provided. Can we add the collateral to the loan without providing disclosures?

You can add collateral by modification unless your State prohibits it (original note still in effect). Since it's not their PR, no ROR is involved either.

Does your response mean that we can add the collateral without providing any disclosures?

Yes, so long as you are not refinancing (new note replacing old note)

But did you just turn your line of credit into a HELOC?

Crud! I didn't even notice LOC! Thanks, Kathleen!!

Back to my origianl question, would any additional disclosures be needed? This is not the borrower's principal residence and there is no new money being advanced.

You would need to disclose and bill as a HELOC. You are creating a HELOC plan. Do you have one that fits?

Am I correct in stating that you are referring to the disclosures required under 1026.40?

Yes. Your line will be a HELOC.