Recently, I listened to a webinar that discussed 5 types of loans that are covered by Reg Z or RESPA, but not both. For Reg Z, it listed mobile home loans, loans secured by 25 or more acres, vacant land, and construction-only. For RESPA only, it listed non-creditor loans. This is probably a ridiculous question, but what is a non-creditor loan?

Review the definition of federally related mortgage loan in RESPA. It tells you who is a creditor for RESPA as part of what is covered.

(D) Is made in whole or in part by a “creditor,” as defined in section 103(g) of the Consumer Credit Protection Act (15 U.S.C. 1602(g)), that makes or invests in residential real estate loans aggregating more than $1,000,000 per year. For purposes of this definition, the term “creditor” does not include any agency or instrumentality of any State, and the term “residential real estate loan” means any loan secured by residential real property, including single-family and multifamily residential property;