We have a borrower who is purchasing what will be his primary dwelling. We are also taking a lien on his parent's primary dwelling. Do the parents have the right of rescission?

My first thought is that it is a residential mortgage transaction so no rescission applies. On the other hand, it is similar to the example in Reg Z where on a construction loan rescission does apply if you also take a lien on the borrower's current primary dwelling, so I'm thinking the parents should have the right to rescind.

Anyone else have an opinion?

I believe that this meets the definition of "bridge loan" so a RofR is required to the parent's.

It's not a bridge loan, it's a 30 year mortgage. It meets the definition of a residential mortgage transaction, which is why I'm wondering if RoR does not apply because of that, or if RoR does apply because we're taking a lien on someone else's primary dwelling in addition to the dwelling being purchased.

This would not be a RMT for the parents. They get the ROR.

Very trusting parents to subject their home to a 30-yr lien! Yes, they get the ROR.