I am pretty sure that I know the answer to this question, but I need a confirmation. We are doing a modification combining a 1st and 2nd - it is a Hardship Refinance. I say that we do not need any new disclosures or ROR b/c no new money or increase in rate or term. Can anybody confirm this for me?
Thanks a bunch!

usually you only need a new RTC if there is "new money".

I guess my question would be if you are combining the 2 notes into one then wouldn't that mean one of the notes is being satisfied and replaced therefore meeting the definition of a refinancing and requiring new disclosures?

I agree with Dan, it's a stretch, IMO, to justify a "modification" when you are making that big of a change.

Dan...you are so right. I have been thinking about this over and over all morning and after discussing with the LO exactly what they are doing again and re-reading the regs I told them the same thing, they are not really modifying they are refinancing b/c they are using a new note not a modification agreement as was first presented to me. If they want to do a modification then they will have to do them seperatly and still have 2 seperate loans. Right?

That would be my opinion, but read my tag line!!!!

I promise not to send out the hounds!!! LOL!!!

Thanks again Dan!