Berico, you may certainly provide the ROR if you wish and I respect your conservativeness on this issue. However, don't you just love howevers, a trust is not a natural person and the beneficiaries do not have ownership, therefore they are not subject to the ROR unless a state law prevails. Reg. Z, to the best of my knowledge, only addresses the beneficial rights when the trust is a Land Trust. And in the 30+ years I've been around in financing I've never seen a Land Trust.
I would venture a guess this is why you don't have a written opinion from the FRB.
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The opinions expressed are mine and they are not to be taken as legal advice.