If we are authorizing a loan in the amount of $180,000 in which a principal residence is being offered as collateral but the owner of property is not a loan applicant do we have Reg Z disclosure requirements considering the below:

Credit over $25,000 not secured by real property or a dwelling. An extension of credit not secured by real property, or by personal property used or expected to be used as the principal dwelling of the consumer, in which the amount financed exceeds $25,000 or in which there is an express written commitment to extend credit in excess of $25,000.

If the loan is to be secured by real property, regardless who's property it is, your $25,000 exemption is out the window.

Your loan IS secured by real property. Who owns the property is of no consideration. Your loan is covered by Reg Z.