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#2241700 - 08/27/20 08:39 PM Mortgage - changed from business to consumer
anio1424 Offline
Junior Member
Joined: Aug 2018
Posts: 29
Hello, if we have a loan that we felt was a business loan then during the processing we find that it is a consumer purpose. What are the implications to Reg Z? Are we in violation of issuing early disclosures timely?

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Interagency (Reg Z) and CFPB Reg B Appraisal Rules
#2241876 - 09/01/20 06:09 PM Re: Mortgage - changed from business to consumer anio1424
Diane Dean Offline
Joined: Oct 2012
Posts: 92
It's really going to depend on the circumstances involved. If you learned of something new that changed the primary purpose from business to consumer, document the file as to what you learned and when.

If you just made a mistake, there's really no way to fix the fact disclosures went out late; all you can really do is understand what happened and why, provide any necessary training, get the disclosures out as soon as you can and move on.
Diane Dean

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