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Early Disclosures on Existing Loans

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Question: 
Does our bank need to request early disclosures on existing loans that are renewing where the interest rate changes? I am rewriting an existing loan to request the reduction of the rate from 7.25 to 6.5. I'm charging a $250.00 fee origination fee as well. Should we send early disclosures to the customer?
Answer: 

If you refinance the loan (replace loan A with loan B), then you must give all new disclosures. If you are renewing the loan (modifying loan A and not replacing it), then no new disclosures are triggered. Refer to Section 226.20(a).

First published on BankersOnline.com 1/18/10

First published on 01/18/2010

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