We have a residential mortgage loan in which the loan is being guaranteed by two (2) individuals. Considering these individuals are guarantors and not applicants, there are no disclosure requirements to either of the guarantors?????

We are concerned that regulators will consider these individuals as co-borrowers considering that this is a consumer loan although our loan documentation clearly has them as guarantors.

If the loan is not for purchase money then you need the Reg AA co-signer notice. A refi will be considered purchase money if no new money is advanced.