Adding Collateral to a Construction LOC

We currently have a consumer loan to build what will be the borrower's primary residence. The loan is secured not by real estate, but by marketable securities. The customer is wanting to add more money to the loan and pledge the property being constructed as collateral for the additional funds. Would we be able to accomplish this via a modification agreement or we need to rewrite the loan and provide TRID disclosures?

Unless what you are doing is a refinance under 1026.20(a), it would not become subject to disclosures.

For an actual answer to your question, I would refer you to your legal council familiar with any State law that might be an issue for doing so.

I could do it here by modification. But I can't answer for you