Disclosures for Consolidating 2 Home Equity Loans

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Question:

We have a customer with two home equity loans secured by a third and 4th lien. We want to consolidate these into one loan with a small principal payment instead of the current interest only payments. There is no new money. What Disclosures (TIL, RESPA) are required?

Answer:

This is a simple consolidation (refinancing) of two dwelling secured loans that I assume are consumer loans. They are subject to RESPA and Reg Z and therefore must follow the required disclosures just as any other consumer purpose dwelling secured loan would.

First published on BankersOnline.com 5/7/12