Our philosophy is to not make student loans, but every now and then our commercial lenders forget that.
Here is the situation. We have offered the following loan commitment: Total loan is $700,000 of which $550,000 is to buy an interest in a dental practice, $25,000 is for miscellaneous start up costs, and $125,000 is to refinance the new dentist's student loans.
Since the majority of the proceeds are business purpose, does this even fall under the Reg Z student loan disclosure requirements? It talks about multi-purpose loans, but I'm wondering if this would even apply since most of the funds are not consumer related.
Thoughts?