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#393843 - 07/29/05 07:38 PM lending ?
Anonymous
Unregistered

I posted this question earlier but under a similar topic that had already been discussed. Nobody responded so I have decided to repost. Sorry! I have had a bit of a brain [censored]. I am currently in the process of making a commercial loan to purchase cattle. I am taking a second mortgage on the customer's home. I know I would have to do a right to rescind, but would any other RESPA or TIL disclosures apply. I am pretty sure they don't but I want to verify.

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Lending Compliance
#393844 - 07/29/05 07:40 PM Re: lending ?
Anonymous
Unregistered

Nope

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#393845 - 07/29/05 07:52 PM Re: lending ?
Creditcopper Offline
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Creditcopper
Joined: Sep 2004
Posts: 203
Michigan
Anon, I saw your other post too. You mentioned purchasing cattle, is this going to be a business or commercial loan or a consumer loan with consumer note & mtg used? I thought business and commercial loans were exempt from Reg Z.
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#393846 - 07/29/05 07:53 PM Re: lending ?
Anonymous
Unregistered

Actually, correct me if I am wrong, but commercial loans are exempt from RoR, no?

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#393847 - 07/29/05 08:32 PM Re: lending ?
HRH Okie Banker Offline
Power Poster
Joined: Jan 2003
Posts: 3,070
Oklahoma
If the loan qualifies for Reg Z exemptions the R or R would not be required.
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#393848 - 07/29/05 10:10 PM Re: lending ?
Anonymous
Unregistered

Comm/Ag Loan sec by cattle & 2nd on Primary Residence - No on RESPA; No on TIL - thus no R of R; HMDA if you are a HMDA reporting bank; get a flood cert; give appraisal notice; get joint application confirmation is 2 applicants. That's all I can think of that applies.

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