We offer a 24-month interest only loan to purchase a residential lot. Upon maturity, the loan will either be refinanced for a longer term to include P&I payments or it may be paid off with a construction loan.

My question: Is the 24-month interest only loan covered by SAFE Act/Reg Z NMLS disclosure requirements?

Bare land - no

1026.36(g) Name and NMLSR ID on loan documents. (1) For a consumer credit transaction secured by a dwelling,

Does this include open-end lines of credit - HELOCs?

I don't believe the Reg Z requirements apply to HELOCS.

1026.36(b) - This section does not apply to a home equity line of credit subject to § 1026.40, except that paragraphs (h) and (i) of this section apply to such credit when secured by the consumer's principal dwelling and paragraph (c)(3) applies to such credit when secured by a dwelling.

(NMLS requirements are paragraph (g))


Just SAFE Act (before acting as MLO, first communication, upon request)