I am doing file reviews and found two loans that I think should have been subject to REGZ.

Purpose - Pay off personal credit cards
Security - Rental Property. Refinancing current loan on the rental and paying off personal credit cards.

Purpose - Purchase Second Home in another state
Security - Rental Property that they own free and clear.


I'm thinking that since these loans are for a consumer purpose, they are subject to REGZ and we needed to use the LE and CD instead of a GFE and HUD1A. If this is correct, can someone tell me where I can find it in a Reg before I bring it to the attention of the lending manager. I think I'm clear on the Second Home one because they will most likely be occupying the property more than 14 days a year, but not sure about the other since it's a dual purpose.

#1 - you added a purpose in the security section of your statement. How much was refinance of the rental property and how much went to personal credit cards?

#2 - Second home non-rental property is personal purpose regardless of the 14 day rule.

#1 - Payoff was 74K and 8K in credit cards.

#2 - I was thinking about the 14 day rule incase the lender came back and tried to say it was really a rental because they are going to rent out when they are not there.

Primary purpose of #1 is still commercial