We are doing a first mortgage to pay off a HUD loan plus part of a second mortage from another bank. Then we are going to do a second mortgage to finish paying of the other second mortgage plus give customer some $$$ for other debt. Our question is since we are doing these at the same time, do we need double early disclosures, HUD statement, GFE, right of rescission, etc?

I'm sure someone will correct me if I'm wrong, but I believe 2 loans = 2 sets of disclosures.