I am almost certain I sat through a training that stated an early TIL is required for business purpose credits secured by owner occupied 1-4 family real estate. I now cannot find that anywhere? Was I dreaming this or is it the requirement?

Business purpose loans are exempt under Reg Z. The purpose of the loan, not the collateral, is what makes it subject to Reg Z.

I know. That's why I am so confused. I really wish I could find my training that told me that.

There are special rules for owner-occupied rental property....perhaps that's what your thinking of? Check out the commentary to 1003.3 #5.

A good way to think about it is that the main disclosure regulations for lending are Regulation Z (TILA) and Regulation X (RESPA). Neither of these apply to business purpose loans.

Piano Man...if I had to take a stab at your memory banks...I would place a bet that you are thinking about those elusive "business investment" loans that are really personal...you know...the Doctor that decides to buy, remodel and flip since the stock market is bad and when the RE market was better????