We have a customer that because of force-placed insurance being added back to their principal balance, they are getting no principal reduction. We want to lower the rate, keep the payment amount the same and switch to a different variable rate index. The current index is no longer used. Can we do this with a modification, or will the loan require a refinance?
What or is there a regulation that requires a paid loan to be processed within a certain period of time?
If the interest rate disclosed in a promissory note is incorrect (it is lower than what is actually being charged), is that a Reg Z problem? What if the TILA disclosure is within tolerance and is considered correct, could this then be an issue with UDAAP?
If we are still delivering disclosures and statements in paper form, do we have to be concerned with E-SIGN or UETA?
I have a closed-end transaction secured by a principal dwelling which is being refinanced to another closed-end product (no new money). The original transaction provided a right of rescission. Please confirm that the refinance loan is not rescindable since it is with the same lender and no new money is being funded. I can't find a cite for this.