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We have a revolving line of credit that is past maturity. Our special assets department would like to do a forbearance agreement to extend the maturity date for six months and also remove the draw feature of this loan because we are unable to verify income at this time. Thus, this will no longer be a revolving line of credit.
Since this is past maturity and we are removing the draw feature, does this make the loan subject to TRID? Also, would it be subject to subsequent disclosure requirements?
We are trying to determine the best way to proceed.
Thank you.
From the information you’ve given it sounds like you are converting from an open end to a closed end transaction or you have a completely new transaction. Based on these assumptions closed end disclosures would be required and TRID would apply. Take a look at 1026.40-5(iii). Also you may want to review 1026. 40(f).
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