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TIL for Modified Loan?

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

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 8/16/10

First published on 08/16/2010

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