TIL on Ranch Property?

Posted By: QueenBB

TIL on Ranch Property? - 08/30/13 03:38 PM

We have MANY customers who are purchasing land (well over 25 acres) with some type of residence on it for a "business" purpose - however, the "business" is definitely not their line of real business. The "residence" is just a house that the customer may live in occasionally - or not. Would this purchase required a final TIL?
Posted By: Kathleen O. Blanchard

Re: TIL on Ranch Property? - 08/30/13 03:52 PM

Without details on the type of business, it is hard to answer. The bank has to do the analysis and determine if the loan is business purpose or not...nothing to do with collateral.

People can have more than one business.

If it is determined to be business purpose (review the commentary to Reg Z for points to consider) then the loan is not subject to Reg Z.

If the loan is determined to be consumer purpose, those rules will apply as applicable.
Posted By: QueenBB

Re: TIL on Ranch Property? - 08/30/13 04:11 PM

The business would be typical ranching activity - possibly used as deer lease or raising sheep. The loans are made to doctors and lawyers, so this is definitely providing much income for them.
Posted By: Kathleen O. Blanchard

Re: TIL on Ranch Property? - 08/30/13 04:17 PM

If the purchaser is spending a lot on this, and is expecting the venture to be money making, not just a tax write off sitting there to be used occasionally for vacation or to make some money when the land is sold sometime down the road, a bank could very well determine this is a business purpose loan and no consumer disclosures would apply.