Consumer Loan Modification

Posted By: Funky Falcon

Consumer Loan Modification - 04/19/13 04:40 PM

If we're modifying a consumer loan by extending the maturity date, adding a voluntary escrow (it's a mobile home loan), therefore changing the payment - would we have to redisclose a new Truth in Lending disclosure to the customer?

It techinically doesn't meet the definition of a refi, so my gut is telling me no...
Posted By: Richard Insley

Re: Consumer Loan Modification - 04/19/13 04:48 PM

Unless you are satisfying the old note and replacing it with a new one (or adding a variable rate feature), no.