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#1849346 - 09/06/13 02:08 PM Extension of maturity date
Banker57 Offline
Gold Star
Joined: Jul 2010
Posts: 439
Minnesota
In charging a renewal fee to extend the maturity date for an exisiting loan, is a separate notice required to inform the customer of this fee? Customer signature required?
Thank you!

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Lending Compliance
#1849366 - 09/06/13 02:33 PM Re: Extension of maturity date Banker57
rlcarey Offline
10K Club
rlcarey
Joined: Jul 2001
Posts: 85,443
Galveston, TX
The charging of fees is a matter of State law. There are no Federal disclosure requirements on simple extensions.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#1849373 - 09/06/13 02:37 PM Re: Extension of maturity date Banker57
Al Miller Offline
Diamond Poster
Al Miller
Joined: Oct 2000
Posts: 2,416
Pleasanton CA USA
Whether or not you charge a fee is immeterial. You are modifying the terms of the loan and your loan agreement probably requires a written agreement of the modification.

Would I include the amount of the fee in the modification agreement? Of course! Let's not get into a "he said", "she said" arguement down the road. Not disclosing could be considered deceptive.

Is this a Reg. Z Disclosable Event? No, a subsequent event- but Reg. Z does not require disclosure.

Al
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Al Miller, CRCM
Opinions expressed are my own and not necessarily shared by my employer.

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