TILA Disclosures for Assumptions
Issue/Inquiry
The co-borrower on a residential mortgage loan has requested to be released from the obligation. The Bank has agreed to do so, on the condition that another co-signer is added. The terms of the loan are not changing and the Bank is not refinancing it. The transaction will be documented with a restated note or assumption agreement. Is the Bank obligated to make loan disclosures to the co-signer?
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