[Lexegay]

Jack,
In your seminar Integrated Mortgage Disclosures you talked about begining August 2015 vacant land will now require early disclosures. Our loans are closed end but the mortgage has ann open end feature. Any additional funds using the open-end clause will they require the early til’s as well?

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[jholzknecht]

When you make a loan under an open-end clause in the mortgage, that new loan is generally closed-end consumer credit and since it will be secured by real property the new Integrated Mortgage disclosures and rules should be followed.

[Author]

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