I'm not reading that statement the same way.
I read it like:
1) refinanced of covered loans (original loan was a covered loan) Otherwise, shouldn't it just refer to refinances and renewals in general?
2) ONLY require new disclosures if it's ALSO a new transaction under Reg Z.
meaning...modifications or some type of 'renewal' that does not extinguish the original note, would not necessarily require new disclosures.
Last edited by RR Joker; 07/18/16 08:27 PM. Reason: typo
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My opinion only. Not legal advice.
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