Covered borrower purchasing a 1-4 unit investment property- covered transaction?

Consumer credit only, AND excludes loans secured by an interest in a dwelling. Sounds like you're two for two.

Thanks Mtn. Trying to look at all our loan products- does this make sense to you:

Product Covered or Exempt Transaction
Residential Mortgages Exempt
Construction Loans Exempt
Seasonal/Second Homes Exempt
1-4 Unit Investment Exempt
Land Loans Covered if consumer purpose
Home Equity Loans Exempt
Home Equity Lines Exempt
Car Loans Exempt if secured by vehicle being purchased
RV/Motorcycle/Boat/Jet Ski/Snowmobile/ATV Exempt if secured by property being purchased
Personal Unsecured Covered
OD LOC Covered
Collateral Loans (CD/Savings) Not permitted

Yes, that looks right to me.

I'm just wanting to double check on the Home Equity portion... I have read that HELOCS are exempt from MLA rules as defined under 232.3(f)(2); however HE loans fall under the MLA rules as found in Question 2 of the FAQs released today in the Fed Reg...

Please let me know if I misinterpreted something somewhere along the way...

Thanks

The MLA "applies to consumer credit extended by creditors to a covered borrower, as those terms are defined in this part."

And the following is found in the Definitions.

"(2) For purposes of this part, consumer credit does not mean:

(i) Residential mortgages, which are any credit transactions secured by an interest in the covered borrower's dwelling, including transactions to finance the purchase or initial construction of a dwelling, refinance transactions, home equity loans or lines of credit, and reverse mortgages;"