We have subordinate loan products from a state financing agency where the interest rate for the subordinate products are always the same (one has no interest rate period) and they do not have an actual contractual agreement under both Fed and State law. When we reserve these types of loans with the agency, they state it is "reserving/locking" the loans, but again there isn't an actual agreement between the borrower, or agency, or the lender. Would we be required to disclose a revised loan estimate in those cases for the subordinates given there isn't a written agreement and on one of them there isn't even an interest rate?
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"Tact is telling someone to go to [censored] in such a way, they look forward to the trip" Winston Churchill