Disclosing Fees for “Piggyback” Loans or “Simultaneous Second” Liens

Now that credit unions are using the new combined TILA/RESPA disclosures for mortgage loans, questions have arisen about how to disclose the fees for “piggyback” or “simultaneous second” liens. The NAFCU Compliance Blog demystifies the confusing rules and guidance on how to handle these situations. [10/22/15]