Looking for some clarity, the small entity guide does not list investment property as exempt from section 43, however I have found a chart from PP Doc's Inc. that list that it is? If the investment property is underwritten on the consumer side but for business purpose than no Reg Z should apply correct?

Correct. If it is a business purpose loan, then Reg Z will not apply. The department that originates the loan does not make a difference in applicability to Regulation Z.

I would also caution you to be careful of the term 'investment'. This is not defined in the regulation and could be a business investment (rental property) or a consumer investment.

Exactly. I personally bought an "investment" property two and a half years ago. It was a foreclosure that was missing a kitchen, furnace, and water heater; had broken windows, ruined carpet, and a leaky roof. We moved into it 1 week after we took possession of it and have been living in it ever since.

To me and my wife, we view this as an investement- and, for us, it is. A personal investment.

Since there was no business purpose on our loan, it 100% applied to Regulation Z.

Soccer - what specific chart are you referring too - I would like to review it.

Randy:

I sent you a PM