Customer has $75,000 Ag loan on 240 acres (including home). Customer now wants to re-do the loan to add $40,000 to payoff credit card debt of his wife's - that he just found out about. Customer does not want two loans, just one.

Would the new note for $115,000 be a consumer loan (w/all appropriate disclosures) because the purpose of the new funds is consumer or a non-consumer note because the majority of the total amount is non-consumer debt?

Thank you!

The transaction would be exempt from RESPA because it exceeds 25 acres and exempt from Reg Z because it is primarily an agricultural purpose. I would treat as commercial/ag.

12 CFR 226.3(a) Business, commercial, agricultural, or organizational credit. (1) An extension of credit primarily for a business, commercial or agricultural purpose.

Thank you very much! Your help is very appreciated.