Regulation Regarding Change In Terms Escrow

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Question:

Is there anything in the regulation regarding a change in terms with an Escrow Account? The lender has approved to lower interest rate and extend maturity. The loan was originated on 08/11/2011.

Answer:

Having an escrow account tied to the account will not influence the need for additional disclosures. You have to determine whether this action constitutes a refinance under 1026.20. If it does, then all applicable new loan disclosures will apply.

First published on BankersOnline.com 2/25/13