A customer buys property for investment purposes and fixes them up for rental property. He recently purchased a property in foreclosure. The officer did give the borrower a GFE, early TIL, etc. at the time of application. The HUD-1A was completed by a closing agent and the officer did not provide the GFE, so therefore the HUD-1A is not completed correctly. When I read the regulations, if the purpose for the loan is for business purposes, neither RESPA or Reg Z do not comply. I would like some direction on how to handle this file. Do we remove all of the disclosures and forms that are RESPA and Reg Z related from the file?

If the loan has already been done what was the purpose? If purpose was consumer then you are in trouble.

I would had done this loan as a business loan. I would make sure to take our all the consumer related docs from the file and contact the closing agent to correct the HUD and have it resigned. Make sure the note is for business purpose.

If a consumer loan you have 30 days to correct the HUD, but you are in violation with no good faith or early TIL. You cannot fix this.