I was presented with an interesting scenario today that I wanted to get other perspectives on. It seems to me like I am missing something but can't put my finger on it.
Scenario came up in the discussion of the implications for flood insurance from cross-collateralization provisions in a deed-of-trust. Essentially, a commercial loan with real estate is made with a DOT that includes a cross-collateralization provision. Later some other kind of closed end loan, consumer loan is made to the same borrower. Someone is saying this is now TRID covered. It sounds strange to me but it also makes sense because it checks all the boxes: consumer, closed-end, secured by RE.
Does this create a TRID disclosure requirement? Or am I missing something?
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Opinions expressed are my own and do not reflect legal advice or the opinions of my employer.