Can We Exempt this Loan from Regulation Z?
by John Burnett, BOL Guru Guru BIOS
Question: Would there be any exemption from Reg Z for a loan request of $2,100,000. to purchase a 2nd home on a 90 day Single Pay Note with monthly payment of interest based on WSJ Prime. There will be a deed of trust on the property.
Answer: No, there is no exemption if the loan is secured by real estate if the loan is to a consumer for a personal, family, or household purpose, regardless of the size of the loan.
Any exemption would have to be based on the loan purpose. If the loan is actually for business purposes, Regulation Z would not apply.
Your question involved the purchase of a second home. That's not a business purpose.
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