We have a customer who is putting a large sum of money ($100,000) down on his consumer real estate note and would like to re-amortize his payments over the remaining term. What kind of disclosure issues do we run into? We won't be charging a fee for the modification.

If you are doing this through a modification to just lower their amortized payment - there would be no disclosures required.

Awesome, thank you rlcarey!

Just be sure the "modification" does not involve satisfaction of the old note and replacement with a new one. That would meet the definition of a "refinancing" and would trigger new Reg. Z disclosures. (The term "modification" has no legal definition and can mean different things from one bank to the next.)

That was my biggest question Richard Insley. We'll make sure it's a true modification and not a refinance. Thank you.