Just was asked to review a pending loan documentation request (i.e., when can I have my doc's type question) and it is a loan to a family trust secured by a multi use property (contains a 2 unit commercial building and a SFR rental unit) with the proceeds to be used to repair/improve the Commercial Building and trustees primary residence and convert it into a rental with the proceeds from that new rental used to offset the cost of the residential retirement community they are moving to. I don't see how this can not be TRID and do I issue a LE now and do we absorb all costs since it was not provided timely? Any / All guidance appreciated.

Not sure how getting a loan to repair a commercial building and converting a residence into rental property is consumer purpose.

Sounds like business purpose to me. I guess there could be some consideration to whether the Trustee home would be acting as a residence during the conversion, but still seems like the underlying purpose is business.

Thank you, guess I overthink to much!