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#2169857 - 03/23/18 03:37 PM Organization credit for federally related mtg loan
Compliance NABW Offline
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Joined: Oct 2015
Posts: 1,597
If a loan is issued to a LLC for the purpose of doing a construction-perm loan for the primary residence of one of its guarantors, is this subject to RESPA only? "TRID" would not seem to apply as organizational credit is exempt from Reg. Z, but it would still seem to be a consumer purpose loan for a "federally related mortgage loan." Most of what I have come across states that the GFE/HUD now only applies to Reverse Mortgages, but is this another situation where using the GFE/HUD-1 would apply?

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TRID - TILA/RESPA Integrated Disclosures Rule
#2169883 - 03/23/18 04:36 PM Re: Organization credit for federally related mtg loan Compliance NABW
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 79,235
Galveston, TX
Some people think so. But I have always been amazed at the logic that a business entity can borrow for a personal purpose. Sounds like the misuse of the LLC to me. How do they account for that?
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#2169920 - 03/23/18 06:11 PM Re: Organization credit for federally related mtg loan Compliance NABW
Compliance NABW Offline
Diamond Poster
Joined: Oct 2015
Posts: 1,597
Likely agree. Perhaps it is just a single-asset entity to hold the RE for some reason.

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