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#2046893 - 10/29/15 02:05 PM Loan Renewals/Modification
Rsbank Offline
New Poster
Rsbank
Joined: Mar 2013
Posts: 3
How do we process a loan renewal with the new Regs? Before we would have a loan that would mature and we would renew it for another term using just the Note, Modification of Mortgage, TIL and proper disclosures. But now that the TIL is obsolete how do we go about renewing a loan? We do not want to Refinance the loan, we just want to renew it.

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TRID - TILA/RESPA Integrated Disclosures Rule
#2046918 - 10/29/15 02:50 PM Re: Loan Renewals/Modification Rsbank
Red Raiders Offline
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Red Raiders
Joined: May 2013
Posts: 1,055
Compliance Land
If you are having the borrower sign a new promissory note then it meets the "refinance" definition in Regulation Z. In these cases, they should basically be treated like any other refinance and follow all of the applicable regulations. If you were to modify or do a change in terms of your existing note prior to it's maturity then it would not be considered a refinance (generally, although depending on what ou are modifying it could cause it to be a refi) and you wouldn't have to give all of the "normal" disclosures.
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#2051836 - 12/01/15 05:45 PM Re: Loan Renewals/Modification Rsbank
ledfoot Offline
Member
Joined: May 2004
Posts: 93
Georgia
Refinancing vs modification
Can a loan modification be done if the rate increases? It's my understanding that an increase in rate would be considered a refinance.
Please advise
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#2051842 - 12/01/15 05:50 PM Re: Loan Renewals/Modification Rsbank
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 79,618
Galveston, TX
Refer to 1026.20.
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#2051845 - 12/01/15 05:54 PM Re: Loan Renewals/Modification Rsbank
ledfoot Offline
Member
Joined: May 2004
Posts: 93
Georgia
I actually did but am still a little confused about the increase in rate. #4 under 1026.20
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