Learn More - Click Here!

New Reply Thread Options
#2258328 - 08/17/21 08:31 PM Refi of 1-4 family used to store bus inventory
Anonymous
Unregistered

Bank has a loan request from a business customer (who owns restaurants) to refinance a residential property he currently owns and uses to store catering and other inventory he uses for his business. Would TRID or any other RRE regs apply in this scenario?

Return to Top Reply Quote Quick Reply Quick Quote
#2258329 - 08/17/21 08:46 PM Re: Refi of 1-4 family used to store bus inventory Anonymous
raitchjay Online
Power Poster
Joined: Oct 2009
Posts: 8,571
OK
You say refinance the property.....what was the purpose of the original loan that is now being refinanced? Is the borrower a natural person? TRID applies to closed end loans secured by real estate (any real estate) with a consumer purpose.

The loan sounds like it's exempt from TRID.....but we really need to know the answers to these questions to know for sure.
_________________________
I'm fixin' to fix that.

Return to Top Reply Quote Quick Reply Quick Quote
#2258331 - 08/17/21 09:04 PM Re: Refi of 1-4 family used to store bus inventory Anonymous
raitchjay Online
Power Poster
Joined: Oct 2009
Posts: 8,571
OK
You also asked about other residential RE regs.....for HMDA purposes, this doesn't sound like a structure that is being used as a dwelling. I wouldn't treat it as a HMDA loan based on the scenario you presented. Obviously, if the loan is business purpose (or to a non-natural person) and is thereby exempt from Reg. Z, that would exempt it from ATR, but i wouldn't treat it as subject to ATR even if not exempt from Reg. Z, using the same reasoning--the structure isn't being used as a dwelling.
_________________________
I'm fixin' to fix that.

Return to Top Reply Quote Quick Reply Quick Quote
#2258336 - 08/17/21 09:29 PM Re: Refi of 1-4 family used to store bus inventory raitchjay
Anonymous
Unregistered

Original purpose was the same as the current purpose....storage of equipment/inventory of business. This is evident by appraisal pictures. Loan is being made to the consumer, in his personal name, he is a sole proprietor.

Return to Top Reply Quote Quick Reply Quick Quote
#2258337 - 08/17/21 09:30 PM Re: Refi of 1-4 family used to store bus inventory Anonymous
raitchjay Online
Power Poster
Joined: Oct 2009
Posts: 8,571
OK
I guess i don't understand.....why would the borrower need a loan to store equipment and inventory in a building they already own?
Last edited by raitchjay; 08/17/21 09:45 PM.
_________________________
I'm fixin' to fix that.

Return to Top Reply Quote Quick Reply Quick Quote
#2258338 - 08/17/21 09:31 PM Re: Refi of 1-4 family used to store bus inventory Anonymous
raitchjay Online
Power Poster
Joined: Oct 2009
Posts: 8,571
OK
Are you saying the 1st loan purchased the property? Or that the 1st loan purchased inventory and equipment?
Last edited by raitchjay; 08/17/21 09:33 PM.
_________________________
I'm fixin' to fix that.

Return to Top Reply Quote Quick Reply Quick Quote
#2258343 - 08/17/21 11:44 PM Re: Refi of 1-4 family used to store bus inventory Anonymous
Richard Insley Online
Power Poster
Richard Insley
Joined: Oct 2000
Posts: 9,999
Toano, VA
Flood insurance?
_________________________
...gone fishing.

Return to Top Reply Quote Quick Reply Quick Quote
#2258349 - 08/18/21 01:07 PM Re: Refi of 1-4 family used to store bus inventory raitchjay
Anonymous
Unregistered

Yes, first loan purchased the property to be used for business storage/inventory. He had no intentions of ever living there. Our loan is to refinance this original loan.

Return to Top Reply Quote Quick Reply Quick Quote
#2258353 - 08/18/21 01:48 PM Re: Refi of 1-4 family used to store bus inventory Anonymous
raitchjay Online
Power Poster
Joined: Oct 2009
Posts: 8,571
OK
Then no TRID, no HMDA.
_________________________
I'm fixin' to fix that.

Return to Top Reply Quote Quick Reply Quick Quote
#2258354 - 08/18/21 01:49 PM Re: Refi of 1-4 family used to store bus inventory Anonymous
raitchjay Online
Power Poster
Joined: Oct 2009
Posts: 8,571
OK
At least....no HMDA IMO....others may disagree.......
_________________________
I'm fixin' to fix that.

Return to Top Reply Quote Quick Reply Quick Quote
Quick Reply:
HTML is disabled
UBBCode is enabled




Moderator:  MagicCity, P*Q, Truffle Royale