Skip to content

TIL for Modified Loan?

Answered by: 

Question: 
A loan is modified from a HELOC to a fixed rate second mortgage. Is a TIL disclosure to be given to the borrower?
Answer: 

You must do all applicable closed-end disclosures under Subpart C which includes the MDIA disclosures and waiting periods, HPML, GFE, HUD SS, etc. See the Commentary to 226.5b(5). If the consumer and creditor enter into an agreement during the draw period to repay all or part of the principal balance and the amount of available credit will not be replenished as the principal balance is repaid, the creditor must give closed-end credit disclosures pursuant to subpart C for that new agreement. . .

First published on BankersOnline.com 8/16/10

First published on 08/16/2010

Filed under: 
Filed under lending as: 

Banker Store View All

From training, policies, forms, and publications, to office products and occasional gifts, it’s available here:

Banker Store

hot right now

image description

Looking for effective, convenient training on a particular subject?

BOL Learning Connect offers more than 200 courses ON-DEMAND or on CD ROM from AML to Reg Z and every topic in between.

Search Topics