Refi of 1-4 family used to store bus inventory

Bank has a loan request from a business customer (who owns restaurants) to refinance a residential property he currently owns and uses to store catering and other inventory he uses for his business. Would TRID or any other RRE regs apply in this scenario?

You say refinance the property.....what was the purpose of the original loan that is now being refinanced? Is the borrower a natural person? TRID applies to closed end loans secured by real estate (any real estate) with a consumer purpose.

The loan sounds like it's exempt from TRID.....but we really need to know the answers to these questions to know for sure.

You also asked about other residential RE regs.....for HMDA purposes, this doesn't sound like a structure that is being used as a dwelling. I wouldn't treat it as a HMDA loan based on the scenario you presented. Obviously, if the loan is business purpose (or to a non-natural person) and is thereby exempt from Reg. Z, that would exempt it from ATR, but i wouldn't treat it as subject to ATR even if not exempt from Reg. Z, using the same reasoning--the structure isn't being used as a dwelling.

Original purpose was the same as the current purpose....storage of equipment/inventory of business. This is evident by appraisal pictures. Loan is being made to the consumer, in his personal name, he is a sole proprietor.

I guess i don't understand.....why would the borrower need a loan to store equipment and inventory in a building they already own?

Are you saying the 1st loan purchased the property? Or that the 1st loan purchased inventory and equipment?

Flood insurance?

Yes, first loan purchased the property to be used for business storage/inventory. He had no intentions of ever living there. Our loan is to refinance this original loan.

Then no TRID, no HMDA.

At least....no HMDA IMO....others may disagree.......