Are disclosures necessary for a $1MM consumer loan? - Richard Insley and Lucy Griffin

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Are disclosures necessary for a $1MM consumer loan?
by Richard Insley and Lucy Griffin, BOL Guru

Question: I have a lender making a $1MM loan to a consumer to construct a personal residence. The loan is NOT real estate secured. I am finding myself unwilling to accept that there are no disclosure requirements for this transaction, however, I believe it to be exempt from Reg Z,RESPA, HMDA and Flood. Is there something I am overlooking?

Answer by Richard Insley:
BIO AND CONTACT INFO

No.

Answer by Lucy Griffin:
BIO AND CONTACT INFO

By not taking a security interest, you dodge RESPA, HMDA and Flood. Also by not taking a security interest, you are making a loan for more than $25,000 and thus dodge Z.

First published on BankersOnline.com 8/18/03

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