Skip to content
BOL Conferences
Thread Options
#1628192 - 11/14/11 07:35 PM short term loan Reg. Z & RESPA exempt?
Chocaholic Offline
Gold Star
Joined: Aug 2005
Posts: 443
Northwest
We are wanting to make a short term fixed rate loan to an individual to purchase a primary residence, the term is under 1 year. Borrowers will be paying this loan off with long term financing obtained from another bank..
Now HMDA this is not reportable,

Does it require GFE & TIL?

Return to Top
Lending Compliance
#1628201 - 11/14/11 07:47 PM Re: short term loan Reg. Z & RESPA exempt? Chocaholic
RR Joker Offline
10K Club
RR Joker
Joined: Nov 2002
Posts: 20,656
The Swamp
Short-term requires disclosure. It's not temporary financing because no longer term financing is expected to pay it out.
_________________________
My opinion only. Not legal advice.

Say you'll haunt me - Stone Sour

Return to Top
#1628205 - 11/14/11 07:51 PM Re: short term loan Reg. Z & RESPA exempt? RR Joker
Chocaholic Offline
Gold Star
Joined: Aug 2005
Posts: 443
Northwest
I am confused, if the borrowers will be obtaining long term financing to pay this under 1 year loan off.. I think this makes it temporary financing right? and therefore not covered under TIL & RESPA

Return to Top
#1628206 - 11/14/11 07:53 PM Re: short term loan Reg. Z & RESPA exempt? Chocaholic
RR Joker Offline
10K Club
RR Joker
Joined: Nov 2002
Posts: 20,656
The Swamp
I'm sorry, I totally missed that and it's plain as day up there...so sorry!

It does not require early disclosures. Do you have a takeout letter? Otherwise you 'may' be making the permanent loan and my bank would disclose in that situation.
_________________________
My opinion only. Not legal advice.

Say you'll haunt me - Stone Sour

Return to Top

Moderator:  Andy_Z