When reading section 609(g), I noticed that the section requires the disclosure of the credit score (and other information) if making a loan against "residential real property." For those of you who have a better handle on this new requirement, is residential real property limited to the consumer's primary residence? Or does this apply in second home and rental property loans where the collateral is residential real property - just not the consumer's primary residence? Thanks.

All 1-4 residential real estate for consumer purposes. Not just an applicant's primary residence.

What about 1-4 faminly non-owner occupied? Also, this is a consumer law, does it apply to trusts or businesses that purchase or refi 1-4 families?

I believe 212(g) refers specifically as applying to "consumer" loans. As in " . . .[an]application initiated or sought by a consumer."

If the loan falls under Reg. Z's exemption for non-owner occupied rental property, it would not fall within a consumer purpose.

I've never seen a trust or business have a credit score.

Would there be anything wrong with going ahead and disclosing credit score and factors on all real estate secured loans as a blanket move to avoid possible under disclosure by our lenders?

Nevermind. I think 212 makes it clear enough.

Currently we are sending this credit score disclosure to all applicants at the time of doc draw. 212 makes it sound like we only need to send this to applicants upon their request. And yet aren't we also supposed to be supplying this info to the denied applicants in every case? Perhaps it would be prudent to simply send it to all applicants, regardless of the action taken on the loan??

Are we only required to send the notice with regards to applications taken on or after 12/1/04?