Reg Z states that you do not have to provide the right to rescind on an open end loan if the home used as collateral is not the consumer's principal dwelling. What if the home used as collateral is the 2nd home that the applicant's inhabit 1/2 of the time, how do you determine which home is the principal dwelling?

The reg says the consumer can only have one primary residence. The rule of thumb would be the address they currently are occupying. However, in some cases it may be more prudent to over disclose and provide the ROR if in doubt.

That is what we were thinking. Thanks.