Refinances & Modifications: Regulation B Considerations
If you have a “refinance”, as defined by Regulation Z (Truth in Lending) in 12 CFR 1026.20(a), you are generally required to provide all new disclosures. There are some instances, for example, if the new loan does not satisfy and replace the existing loan, where new disclosures are not required. That’s only taking into consideration Regulation Z; however, other regulatory requirements do still apply such as Regulation B. It’s very important that you understand when you have an application under Regulation B, which might trigger other requirements/disclosures, joint intent, appraisal disclosure, government monitoring information, adverse action notices, etc.
Kevin explains more in the video.
Published
2023/08/24
Kevin Edwards
Kevin brings years of experience and a unique perspective on regulatory matters to our clients. A self-proclaimed geek and accredited CRCM, Kevin is also a recovering attorney with experience as in-house counsel for a large regional bank and one of the leading national title insurance providers. For reasons unknown, Kevin decided to leave the safety and serenity of his desk job to seek fortune and glory as a wandering adventurer. Like a bank compliance version of Kwai Chang Caine, The Man with No Name or Don Quixote, he now travels the land seeking to help those in need and righting compliance wrongs, wherever he may find them. Kevin lives in Sioux Falls with his two children, who are surprisingly normal after having endured their father’s vivid imagination for their entire lives. He won’t admit to having any hobbies, because apparently “Regulations never sleep.” (While he does say this in his Batman voice, we’re pretty sure he’s joking.) From the looks of his Facebook page, he likes the outdoors and spending time with his large extended family (who seem like relatively normal people).