What regs apply to this case?
by Dan Persfull and Richard Insley, BOL Guru Guru BIOS
Question: If the collateral is commercial or rental R/E, and the loan proceeds will be used to purchase a new home and remodel it, will RESPA, Reg Z and Reg B apply in this case? We are a non-HMDA bank.
Answer by Dan Persfull: Reg. B will apply.
You don't say what the purpose of the "new home" is. If it's another rental property RESPA and Z will not apply, but if it's for the borrower's dwelling, or other consumer purpose RESPA and Z would apply.
Answer by Richard Insley: Never forget flood insurance when the property has improvements.
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