Is "Real Property" as mentioned in 103.33(a) referring to anything tangible such as land or an automobile? Also, that section states the record to retain must contain the "nature or purpose" of the credit. Do you think "for personal use" or something generic like that is acceptable or does it need to be more specific like "to purchase a vehicle"?

"Real property" generally equates to an interest in real estate, anything from surface rights, to mineral rights, to air space above the real estate qualifies. To summarize, they are talking about "dirt."

What is acceptable as a statement of purpose has been the subject of an ongoing debate. My answer is the only "statement of purpose" that could mean anything is one that would allow a third party reviewer to "chase proceeds." In other words, can a third party reviewer compare what the borrow did with the funds as opposed to what he said he was going to do? A statement of purpose that says "Personal" is worthless. One that says "purchase vehicle" gives them something to go on. A statement of purpose that indicates "business" is also worthless. One that says "planting expenses" tells them something.

Although required by BSA regulations on many loans, bank loan policies also often require a specific statement of purpose for many loans - check your bank's loan policy.

Woe is me. Anon is me too.

Thank you, Ken. It's nice when someone else backs your own opinion!