We have been tossing this question around in the Loan Department and I think we have totally confused ourselves! Since the MDIA changes to Reg Z on 7/30 do you have to do a TIL on a loan to a Trust secured by a dwelling? Example: Couple buys a second home in their Trust name - I know the Trust is not a natural person and this was clear to us no TIL was needed before the Reg Z changes, but since it is a "consumer dwelling" they are buying would the TIL be necessary?

It's not a consumer's dwelling if the trust owns it. The trust is not a consumer.

As always, thank you Dan! With all of these changes the most basic things have become confusing.

Not to muddy the waters, but we do the loan to the trust and the borrowers as individuals in case they decide to take it out of the trust during the life of the loan. We do disclosures to the individuals.

In that case you would only have to do a TIL at closing because you are now making the loan to a "natural person". The dwelling however is still not a consumer's dwelling because it is owned by the trust at the time you made the loan, therefore 226.19(a) would not apply.