Disclosure of Interest

Are we required to disclose interest on a renewal on the Good Faith and HUD-1A? This is interest on the previous loan from last payment, accrued the the maturity/renewal date? If it is a requirement, can you tell me where it is required to be disclosed on both documents.
Stephanie

Interest from the prior loan, is not a fee on your current loan. GFE's are for fees of a new loan.

HUD-1A would reflect the interest as part of the overall payoff of the prior loan, but not as an individual item.

Remember these are two individual loans, never the twian shall meet.

I understand what you are saying regarding the Good Faith but I want to clarify the answer to the HUD-1A.

This is a "renewal" not a "refinance". Our renewals have the same loan number and interest cannot be rolled, therefore, it has to be paid by the borrower at closing. You refer to showing it as an overall payoff but we cannot show the interest included in payoff.

If this is a true renewal then RESPA does not apply and there is no need for a GFE or a HUD SS.

However, if you are having a new note signed (which it sounds like you are) that satisfies and replaces the current note you have a refinancing regardless of your internal account numbering system.

If you insist on showing the accrued interest separately you would disclose it on one of the blank lines in the 1500 series of the HUD 1A. It is not dislcosed on the GFE.

Dan is correct. You need to decide if this is a modification or a refinance. If the note is retained its a modification no disclosures, or HUD1. If the note is replaced it is a refinance regardless of what you call it.