Answer:
There is no exemption as you suspected. The order of your lien has no bearing on your disclosure responsibilities.
Early TIL/GFE for 3rd Mortgage Loan
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Question:
We are making a 3rd mortgage loan to a current customer. It seems ridiculous, but as far as I can tell we need to provide an early TIL & GFE. Is there an exemption somewhere I have missed?
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