We have a loan made on commercial property in January 2012 for $32,000 for personal purpose, made to an individual. is this loan subject to reg z disclosures and GFE?

thanks,

Duke

Regulation Z is purpose driven and it not dependant on the type of collateral. You don't give enough information to determine the applicability of RESPA.

yes, it's purpose is to pay off personal debt. but the amount is only $32,000. does that mean it's exempt?

what info do you need to know for RESPA?

Thanks!

The dollar amount threshold for Regulation Z is now $51,800, however if it is real property secured it is covered regardless of amount. Is this commercial property 1-4 family property?

it is a commercial property - storefront.

Then RESPA will not apply.

Thank you very much!

I have one more question... since we have determined that this loan falls under regulation z, but not Reg X, what about the interest rate? Should the bank have offered the consumer terms like a rate of let's say 4.25 instead of 7.5%? Is this now a Higher Priced Mortgage?

think I just found it - only if loan was secured by principal residence.