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#2231233 - 02/18/20 10:24 PM Bridge loan subject to Reg Z?
cwscb Offline
Junior Member
Joined: Jan 2018
Posts: 31
Is the following subject to Reg Z, with all the early disclosures (loan estimate, etc.)?

- A 6-month bridge loan to pay off Borrower's existing mortgage loan against an investment dwelling outside the U.S.
- The 6-month loan will be against a 3rd deed on Borrower's principal residence in the U.S.

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Lending Compliance
#2231238 - 02/18/20 11:29 PM Re: Bridge loan subject to Reg Z? cwscb
rlcarey Online
10K Club
rlcarey
Joined: Jul 2001
Posts: 83,227
Galveston, TX
A consumer purpose loan secured by real property is always subject to Regulation Z and TRID.
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#2231834 - 02/26/20 10:48 PM Re: Bridge loan subject to Reg Z? cwscb
MyKidsMom Offline
Platinum Poster
MyKidsMom
Joined: May 2004
Posts: 641
TEXAS
But is it subject to the HMPL/HOEPA rules?

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#2231962 - 02/27/20 09:01 PM Re: Bridge loan subject to Reg Z? cwscb
Dan Persfull Offline
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Dan Persfull
Joined: Aug 2002
Posts: 47,517
Bloomington, IN
HOEPA - see 1026.32(a)(2) for the exemptions.

HPML - see 1026.43(c)(2) for the exemptions.
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The opinions expressed are mine and they are not to be taken as legal advice.

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