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#2246507 - 12/14/20 07:05 PM TRID disclosures for a modification
compliance75 Offline
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Joined: Oct 2016
Posts: 105
For a construction loan where we are only extending the interest only period, and as a result the P&I payments will increase while maturity date remains the same, do we need to provide a new LE and CD? Interest rate remains the same and other terms. Thank you,

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TRID - TILA/RESPA Integrated Disclosures Rule
#2246511 - 12/14/20 07:45 PM Re: TRID disclosures for a modification compliance75
compliance75 Offline
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Joined: Oct 2016
Posts: 105
Also, can we satisfy the disclosure requirements by completing H-4(D)(2) Sample Form for § 1026.20(c)?

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#2246517 - 12/14/20 09:16 PM Re: TRID disclosures for a modification compliance75
Dan Persfull Offline
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Dan Persfull
Joined: Aug 2002
Posts: 47,358
Bloomington, IN
Are you modifying or refinancing (1026.20(a) and its OSI)?

If you have a true modification (the existing note is not being satisfied and replaced) then new disclosures are not required.

Your modification agreement should disclose the terms of the modification complying with any applicable state laws.
_________________________
The opinions expressed are mine and they are not to be taken as legal advice.

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#2246825 - 12/22/20 04:20 PM Re: TRID disclosures for a modification compliance75
MJNoone Offline
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MJNoone
Joined: Dec 2010
Posts: 108
Kansas
Would this be true as well for increases in a Construction Only loan where we are looking at increasing the line to accommodate some cost overruns and extending the maturity date for weather delays?
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M Noone

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#2246838 - 12/22/20 07:15 PM Re: TRID disclosures for a modification compliance75
Dan Persfull Offline
10K Club
Dan Persfull
Joined: Aug 2002
Posts: 47,358
Bloomington, IN
Yes. See 1026.20(a).
_________________________
The opinions expressed are mine and they are not to be taken as legal advice.

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#2246850 - 12/22/20 10:38 PM Re: TRID disclosures for a modification compliance75
Diane Dean Offline
Member
Joined: Oct 2012
Posts: 92
Just don't forget about flood insurance requirements when increasing or extending. It can be easy to do!
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Diane Dean
http://www.bankerscompliance.com

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