I need to check myself here (& get a 2nd opinion) Thanks in advance.

If we do a no cost 2nd mortgage, are the ETIL and GFE (everything POC) still required? Does the answer to this change if the loan closes the day after the application?

Would we still need a Required Provider notice on a no cost loan? Would the HUD stmt take the place of the Require Provider notice on a short turnaround loan?

An Early TIL is only required if the 2nd is made as part of a residential mortage transaction - see 226.19(a).

A Good Faith Estimate and Settlement costs booklet will still be required within three business days of application. The GFE should show the charges associated with the transaction, but show them as POC by the lender.

No Servicing Disclosure Statement is required, since the loan in question is not a first lien.

At closing, the HUD-1 or HUD-1A should be prepared similarly.

I agree with redsfan, and would add that I don't believe the required provider disclosure is needed if the borrower is not required to actually pay any portion of the costs.

Also, if it should be a residential mortgage transaction, you just need to provide a TIL within 3 business days of application. If you provide a final TIL at closing, and closing is within 3 days of app, that meets that requirement.

Thanks, that is exactly what I was looking for.

Can you think of any situation where you would not need a GFE on a residential loan, other than providing a denial within 3 days?

Also, finance charges, on a no cost loan, the customer does not pay the LOL monitoring, do we still show it in the finance charge as a prepaid even if the bank is absorbing the cost?

The only exemption for not providing the GFE is if the loan is denied within 3 business days of the application or if the loan is an open-end credit subject to the Reg. Z disclosures.

Charges not paid by the borrower are not finance charges.

Thanks to all for the confirmation.