[mfowler]

Thank you, and appreciate your comment! Any significant changes would institute a refinance.

[mfowler]

In regards to a modification/extension agreement, we have not been charging our customers BUT want to implement a fee. I would not think this would be a prepaid finance charge as we’re not going to know at application who will be modifying/extending their loan.
Would we need to disclose the fee, if any, up front? For compliance purposes, how is the best way to handle this?

[Author]

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