2nd REM in Abundance of Caution-Early Disclosures?

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Question:

If I take a second REM in an abundance of caution for a loan workout situation, are early disclosures required? The loan was originally an auto loan.

Answer:

Yes taking the real estate as collateral triggers all the required disclosures associated with consumer purpose credit secured by 1-4 residential property.

Abundance of caution doesn't mean squat when it comes to regulatory disclosures.

First published on BankersOnline.com 9/26/11