No, I just wanted to be sure I understood your line of thinking.the original borrower is leaving the loan and daughter is taking over the loan and payments
This sounds like the daughter is assuming the loan. Depending on the circumstances the transaction may be subject to new disclosures. Review 1026.20(b).https://www.bankersonline.com/regulations/12-1026-020#20b
On May 1, 2019, the CFPB issued a Fact Sheet, "Are Loan Estimates and Closing Disclosures Required for Assumptions?" Specifically, the Factsheet addresses whether a Loan Estimate and Closing Disclosure are required under the TILA-RESPA Integrated Disclosure Rule (TRID Rule) for a specific group of transactions. It addresses whether these disclosures are required for a transaction: (1) in which a new consumer is being added or substituted as an obligor on an existing consumer credit transaction; (2) that is a closed-end consumer credit transaction secured by real property or a cooperative unit; and (3) that is not a reverse mortgage subject to 12 CFR 1026.33. The Factsheet can be found on the CFPB's Compliance and Guidance page for TILA-RESPA Integrated Disclosures.