I have a case where an individual lent another person the money to purchase a house from him. The bank then took an assignment of the note from him with recourse. The individual did not provide RESPA and TIL disclosures. Is the bank required to provide disclosures under these regulations for assignments?

Also, would the bank report this assignment as a purchase under HMDA?

Thank you for any help you can give me on this.

No, taking an assignment is not making a federally related mortgage loan. They also are not HMDA reportable.

What is the difference between an assignment and a purchase for HMDA purposes? Thank you.