A loan is for a second home >$25,000. Since it is not secured by the primary residence it is exempt from Reg Z, but that does not mean that it is exempt from RESPA, right? I have it in my mind that RESPA relies on Reg Z to determine if a transaction is exempt.

RESPA relies on Reg. Z's definition of business credit. However, a 2nd home is not business credit, and so is neither exempt from Reg. Z nor RESPA.

There are portions of Reg. Z that do not apply based on the fact that it isn't the borrower's primary residence, but Reg. Z itself does.

I read the Reg. Z exemption to be for consumer credit greater than $25M and not secured by a principal dwelling or real property. You'll still have real property and will they occupy it part of the year? The second home is not business purpose if they'll occupy it more than 14 days a year. (See OSC 226.3 3)

So, if a ranch is purchased for >25 acres with a 1-4 dwelling (not business purpose)included, it is RESPA exempt, but still requires the early TIL for Reg Z?

RESPA exempts any loan on property >= 25 acres.

Reg Z has no acreage exemptions. ETIL does not apply. The ETIL only applies on loans that are subject to RESPA disclosures 226.19(a)(1). Other provisions of Reg Z would apply.

The > $25,000 exemption in Reg Z only applies to loans not secured by real property (does not have to be a dwelling), or personal property that will be used as the borrower's primary residence.

Thank you. I guess by the time I retire I will speak "regs" fluently. Everytime I think I have all of this down, a new scenario pops up that is covered in yet another section!