I'm not reading that statement the same way.
Last edited by RR Joker; 07/18/16 08:27 PM. Reason: typo
I read it like:
1) refinanced of covered loans (original loan was a covered loan) Otherwise, shouldn't it just refer to refinances and renewals in general?
2) ONLY require new disclosures if it's ALSO a new transaction under Reg Z.
meaning...modifications or some type of 'renewal' that does not extinguish the original note, would not necessarily require new disclosures.
My opinion only. Not legal advice.
Say you'll haunt me - Stone Sour