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#2188391 - 08/08/18 10:21 AM Which purpose is this?
IUalum Offline
Platinum Poster

Registered: 03/28/02
Posts: 933
Loc: Kentucky
I'm racking my brain on this one. Customer is refinancing their current residence, paying off other consumer debts and also purchasing a vacant lot, all in the same transaction. I would normally just say this is a cash-out refi, but the purchase of the lot has me confused. Would the purchase be outside the refi transaction here and the amount just be disclosed as cash out to the customer? Our processor is confused as to how to disclose the fees for deed transfer etc. to the seller of the lot. The more I think about it, the more baffled I get. Can anyone give me some guidance here?
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TRID - TILA/RESPA Integrated Disclosures Rule
#2188394 - 08/08/18 10:33 AM Re: Which purpose is this? [Re: IUalum]
raitchjay Offline
Power Poster

Registered: 10/15/09
Posts: 7653
Loc: OK
The answer depends on what you're secured by. If only secured by the primary residence, then your purpose is "refinance". If also secured by the lot being purchased, then your purpose is "purchase".
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#2188396 - 08/08/18 10:37 AM Re: Which purpose is this? [Re: raitchjay]
IUalum Offline
Platinum Poster

Registered: 03/28/02
Posts: 933
Loc: Kentucky
Thanks!
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#2188397 - 08/08/18 10:38 AM Re: Which purpose is this? [Re: IUalum]
raitchjay Offline
Power Poster

Registered: 10/15/09
Posts: 7653
Loc: OK
Sorry got distracted midway through......if the lot isn't your security, then i'd show the amount for the lot in Payoffs and Payments, just like a mobile home only purchase.
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#2188399 - 08/08/18 10:40 AM Re: Which purpose is this? [Re: raitchjay]
IUalum Offline
Platinum Poster

Registered: 03/28/02
Posts: 933
Loc: Kentucky
Yes, turns out we ARE taking the lot as security. I wasn't sure at first.
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#2188444 - 08/08/18 02:07 PM Re: Which purpose is this? [Re: IUalum]
Compliance NABW Offline
Diamond Poster

Registered: 10/22/15
Posts: 1120
Then, you do have a "Purchase" and would need to include the details of the transaction related to the lot purchase. If the lot was not being used as security, then you could pretty much refer to this thread:

https://www.bankersonline.com/forum/ubbthreads.php/topics/2188255/re-what-spl-to-use#Post2188255

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