The loan officer is going to have to chill out, and I suggest keeping a compliance-eye on anyone trying to pull something like this "ASAP."
This has to start with an application. Assuming it's a consumer-purpose loan, there has to be an LE and CloD issued, the timing requirements have to be met, and the ATR requirements in 1026.43 will undoubtedly apply. You'll need to check out applicability of HOEPA and HPML, etc., etc., etc.
This doesn't look like it's even remotely eligible for a modification.
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8