Sorry but this is a confusing deal...need assistance.
Borrower is purchasing a strip center and will be using his personal residence and the strip center for collateral. Since his personal residence is involved, I would like confirmation on the following?
1. RESPA disclosures-yes
2. REG Z disclosures-yes
3. HMDA- Don't believe so
4. Right of Rescission-yes

It's the purpose that determines whether or not it's a consumer purpose loan, not the collateral. I believe you have a busines purpose loan so 1,2 and 4 are no. 3 is no unless part of the money is being used to payoff another dwelling secured loan to the same borrower.

If teh "strip center" is a business, this is a business PURPOSE loan and RESPA and Reg Z do NOT apply (including RofR). Collateral is the 2nd test not the first. HMDA would not apply either as they are not purchasing or improving the dwelling or refinancing a dwelling secured loan.

Thank you both for your help.