Answer:
If you modify a loan without refinancing it [refer to 226.20(a)], then it is not subject to new disclosures or new TIL requirements (including HPML). No escrow requirements would apply.
First published on BankersOnline.com 5/17/10
Amend Loan Without Rewriting It?
Answered by:
Question:
We have several loans that have an advance clause as a part of them. If the loan is an HPML, could we amend the loan without re-writing and avoid the escrow issue? The terms and condition would remain the same. The payment would change. Would we have to escrow the amount of the advance if the loan is not re-written?
print
share