On a consumer loan to individuals who are trustees of Revocable Trusts (each spouse has a Revocable Trust), where the loan is secured by the dwelling owned by the trusts, and where that dwelling secures the loan (which is the trustees' principal dwelling); does the Revocable Trusts have ROR?

I'm thinking no since they the Trusts are not natural persons, even though for the test to determine if it is a consumer purpose loan a Trust would be considered a natural person.

Official Interpretation
2(a)(11) Consumer
2. Rescission rules. For purposes of rescission under §§1026.15 and 1026.23, a consumer includes any natural person whose ownership interest in his or her principal dwelling is subject to the risk of loss. Thus, if a security interest is taken in A's ownership interest in a house and that house is A's principal dwelling, A is a consumer for purposes of rescission, even if A is not liable, either primarily or secondarily, on the underlying consumer credit transaction. An ownership interest does not include, for example, leaseholds or inchoate rights, such as dower.
3. Trusts. Credit extended to trusts established for tax or estate planning purposes or to land trusts, as described in comment 3(a)-10, is considered to be extended to a natural person for purposes of the definition of consumer.

• Comment 3(a)- 10 Trusts. Credit extended for consumer purposes to certain trusts is considered to be credit extended to a natural person rather than credit extended to an organization. Specifically:
i. Trusts for tax or estate planning purposes. In some instances, a creditor may extend credit for consumer purposes to a trust that a consumer has created for tax or estate planning purposes (or both). Consumers sometimes place their assets in trust, with themselves or themselves and their families or other prospective heirs as beneficiaries, to obtain certain tax benefits and to facilitate the future administration of their estates. During their lifetimes, however, such consumers may continue to use the assets and/or income of such trusts as their property. A creditor extending credit to finance the acquisition of, for example, a consumer's dwelling that is held in such a trust, or to refinance existing debt secured by such a dwelling, may prepare the note, security instrument, and similar loan documents for execution by a trustee, rather than the beneficiaries of the trust. Regardless of the capacity or capacities in which the loan documents are executed, assuming the transaction is primarily for personal, family, or household purposes, the transaction is subject to the regulation because in substance (if not form) consumer credit is being extended.
ii. Land trusts. In some jurisdictions, a financial institution financing a residential real estate transaction for an individual uses a land trust mechanism. Title to the property is conveyed to the land trust for which the financial institution itself is trustee. The underlying installment note is executed by the financial institution in its capacity as trustee and payment is secured by a trust deed, reflecting title in the financial institution as trustee. In some instances, the consumer executes a personal guaranty of the indebtedness. The note provides that it is payable only out of the property specifically described in the trust deed and that the trustee has no personal liability on the note. Assuming the transactions are primarily for personal, family, or household purposes, these transactions are subject to the regulation because in substance (if not form) consumer credit is being extended.

The trustees have a right of rescission.

Regardless of the capacity or capacities in which the loan documents are executed, assuming the transaction is primarily for personal, family, or household purposes, the transaction is subject to the regulation because in substance (if not form) consumer credit is being extended.

Thank you.

Would they be listed as themselves such as John Doe only; or as John Doe, Trustee for John Doe Revocable Trust?

Which is it, a loan to individuals where the collateral is held by a trust or a loan to a trust?
I ask because that will determine how your documents are drawn and signed.
Because the trust has no income, we qualify the individuals for the loan.
Our documents therefore read: John Smith and Mary Smith, husband and wife and John Smith, Trustee and Mary Smith, Trustee of the Smith Family Trust.
There are four signature lines: John Smith; John Smith as Trustee; Mary Smith and Mary Smith as Trustee.
It's easy to see how the way we prepare docs makes the need for the RoR more apparent too.

This loan is to the individuals themselves, John Doe and Jane Doe. The dwelling is held by two trusts, John Doe, Revocable Trust with John Doe as Trustee and Jane Doe, Revocable Trust with Jane Doe as Trustee.

The right of rescission notice will be issued to John Doe and to Jane Doe, and will be acknowledged (if you have them acknowledged) by John Doe and by Jane Doe.

Ask bank counsel whether the note will be signed by the two individuals or by the two individuals and the two trustees.