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modifications

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  • March 22, 2017 at 8:47 am EDT #10774
    mdunker
    Member

    In the world of TRID can we do a modification to lower the interest rate?

    If so do we still need to comply with ATR and QM rules?

    What else would be required if we do a modification?

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  • March 22, 2017 at 1:20 pm EDT #10780
    rcooper
    Member

    Yes, you can use a modification to lower the interest rate. If the modification doesn’t meet the definition of a refinance under Regulation Z (1026.20(a)) the ATR/QM rules would not be applicable. If the modification is a refinance the ATR/QM rules would be applicable.

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