I'm trying to determine when an assumption policy is required on the TIL disclosure. We've only been disclosing it on purchase money loans subject to RESPA. We have examiners here that say it should be on our construction loans TILs also, even if they are not subject to RESPA. Can someone please help me out? I've been thinking that the definition of a residential mortgage transaction is a purchase money transaction subject to RESPA.

There is no temporary financing exclusion in Reg Z for a RMT.

Thank you for your response- the last two weeks with the examiners have turned my brain to mush, and when I went back and looked, we do have correct procedures in place. Of course, the loan they were looking at did not get done correctly because an incorrect product was chosen in our loan documentation software!