In most cases, new Truth in Lending disclosures are not required when you modify an existing loan. But, you have to be careful that what you call a modification is not actually a “refinance” under Regulation Z, which does require new disclosures. If we step outside Regulation Z, however, and look at the Flood requirements, it really doesn’t matter if you have a refinance or a modification, because flood will likely always come into play.
Kevin explains more in the video.
Video Highlights:
- A bank must not make, increase, renew, extend (MIRE) without following flood rules.
- This may include a Special Flood Hazard Determination, flood Notice, flood insurance, etc.
- Coverage needs to be recalculated every time there's an MIRE event.
Published
2023/10/22
