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#199033 - 06/10/04 03:55 PM Early TIL
Anonymous
Unregistered

Are early TILs required on a purchase of land to be used for future consumer purpose? How about consumer purpose bridge or (construction loans w/out transfer of title? Any help would be great. thanks

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Lending Compliance
#199034 - 06/10/04 04:03 PM Re: Early TIL
Dan Persfull Offline
10K Club
Dan Persfull
Joined: Aug 2002
Posts: 47,517
Bloomington, IN
Supplement I, 226.19: Certain Residential Mortgage and Variable-Rate Transactions (01/01/02)

Paragraph 19(a)(1) Time of disclosure.

1. Coverage. This section requires early disclosure of credit terms in residential mortgage transactions that are also subject to the Real Estate Settlement Procedures Act (RESPA) and its implementing Regulation X, administered by the Department of Housing and Urban Development (HUD). To be covered by this section, a transaction must be both a residential mortgage transaction under ยง226.2(a) and a federally related mortgage loan under RESPA. "Federally related mortgage loan" is defined under RESPA (12 USC 2602) and Regulation X (24 CFR 3500.5(b)), and is subject to any interpretations by HUD.
_________________________
The opinions expressed are mine and they are not to be taken as legal advice.

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#199035 - 06/10/04 04:16 PM Re: Early TIL
Anonymous
Unregistered

Thnaks for the info. I am new to compliance but do think I have a solid understanding of RESPA. It is Reg Z that still evades my full understanding. Based on what wa sposted previously and my understanding of RESPA then neither a bridge loan or a land loan would be subject to early reg z disclosure because land does not meet the RESPA definition of a "fed related mortgage loan" and the bridge loan is exempt from RESPA as temporary financing. Or would the bridge loan be cover because it is a "fed realted mortgage loan" and the RESPA exemption is irrelevant to the early reg z requirement?

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#199036 - 06/10/04 04:32 PM Re: Early TIL
Dan Persfull Offline
10K Club
Dan Persfull
Joined: Aug 2002
Posts: 47,517
Bloomington, IN
Your reasoning is correct. Those loans are exempt.

The loan has to be BOTH a residential mortgage transaction under Reg Z and a federally related mortgage loan under RESPA. Not one or the other.
_________________________
The opinions expressed are mine and they are not to be taken as legal advice.

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#199037 - 06/10/04 04:42 PM Re: Early TIL
Anonymous
Unregistered

Thanks so much for your help!

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