I'll second Dan's recommendation that you review section 215.5(c) and ensure that the refinancing will fit precisely the restriction in 215.5(c)(2). If it won't fit there, it has to fit the "default" bucket in 215.5(c)(4), and that has a $100,000 cap.
There's also the requirement in 215.5(d) that the bank have on file a current personal financial statement of the EO and that the loan agreement include the demand clause (or have a rider with the demand clause) required by 215.5(d)(4).
Last edited by John Burnett; 02/13/15 10:08 PM. Reason: correction
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
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