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#627034 - 10/20/06 12:48 PM ROR Question
ACBbank Offline
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ACBbank
Joined: Jul 2006
Posts: 4,350
New York City
We are doing a HELOC for a Trust. We are planning on having the Trustee sign the ROR, but do the guarantors need to sign an ROR as well?
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"100 victories in 100 battles isnt the most skillful. Subduing the other's military w/o battle is the most skillful." Sun-Tzu

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Lending Compliance
#627035 - 10/20/06 12:54 PM Re: ROR Question
Dan Persfull Offline
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Dan Persfull
Joined: Aug 2002
Posts: 47,533
Bloomington, IN
A loan to a trust, other than a bona fide land trust, is not subject to the provisions of Reg. Z. A trust is not a natural person.
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The opinions expressed are mine and they are not to be taken as legal advice.

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#627036 - 10/20/06 01:07 PM Re: ROR Question
ACBbank Offline
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ACBbank
Joined: Jul 2006
Posts: 4,350
New York City
So no ROR is required at all?
_________________________
"100 victories in 100 battles isnt the most skillful. Subduing the other's military w/o battle is the most skillful." Sun-Tzu

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#627037 - 10/20/06 01:21 PM Re: ROR Question
Dan Persfull Offline
10K Club
Dan Persfull
Joined: Aug 2002
Posts: 47,533
Bloomington, IN
If the transaction is exempt from a specific reg then it is exempt from all of its provisions.
_________________________
The opinions expressed are mine and they are not to be taken as legal advice.

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#627038 - 10/20/06 01:27 PM Re: ROR Question
ACBbank Offline
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ACBbank
Joined: Jul 2006
Posts: 4,350
New York City
Thanks Dan. I dont usually handles the HELOCs and just wanted to be sure.
_________________________
"100 victories in 100 battles isnt the most skillful. Subduing the other's military w/o battle is the most skillful." Sun-Tzu

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