An applicant applies for a loan to make improvements on his property but the loan is secured by his parents' home; they are not on the application, loan or credit scored..they are only on the mortgage which is a first lien. I know a Servicing Disclosure is required but should it be to the borrower or parents or both?

Thank you for your response.

Is your loan secured by a second lien on the parents' home?

From 3500.21(b)

. . . provide to each person who applies for such a loan . . .

The disclosure would, IMO, only be required to be given to the applicant(s). The parents are not applicants in this transaction.

But it sounds like a second lien anyway, no?

From this comment in the post I assumed it was a first lien.

I read it too quickly then.

The lien is a first on the parents' home