We are doing a single family home purchase for Mr A. He is purchasing home from Mr B. Mr A currently lives in the home and Mr B will be a cosignor on the loan. Mr A will live there as his primary residence, but we are titling the deed in the name of Mr A's business. So, should we treat this up as a loan to consumer to purchase primary residence? We are using a rate for an investment property (which is higher than primary residence) because it is being titled in the business name (with personal guarantees). Should our disclosures be for the primary residence since that is the purpose of the loan?

Is the loan to Mr. A or Mr. A's business? You might want to reveiw the exemptions in 226.3 and its Commentary.

The loan is to the business to purchase the dwelling in which he lives.
Thanks

226.3(a)(2)