I use the BOL Real Estate Lending Matrix and I am reviewing a situation which is addressed in the matrix but a discussion is occuring about total/separate sets of disclosures. The two loan requests were received at the same time to acquire 1-4 dwelling (primary). The bank would be completing a first and second lien to allow the purchase. From the matrix, it has RESPA, REG Z, ROR, HMDA and Flood as being applicable (I agree), but would you require two Appraisal Notices, two FCRA FACT notices, two Mortgage Servicing,and two flood determinations?

An ultraconservative approach would be to provide all necessary disclosures for each loan as each are in actuality separate transactions, but is this practical?

Has anyone had a similar situation?