Question:
We write a bunch of change of terms every month. The reason for the COTs range from interest only payments, lower interest rates, update delinquencies and change name on the title. I’m looking for your opinion on when we need new Loan Agreements/security agreements. I’m looking to add many of the disclosures from our loan agreement to the back of the COT form, so the member doesn’t have to sign new loan agreements. I am running across confusing language in the regulations. I’ve seen an article that says skip payments and do not require new disclosures because that doesn’t constitute a refinance. I’ve also heard that refinance may involve the rescheduling of payments. My ultimate objective is to make it easier for the loan officers to create COTs. It is very time consuming at the moment.