Earlies needed?

Posted By: Banker57

Earlies needed? - 01/20/15 02:27 PM

Are early disclosures needed for a personal loan to purchase a home, but using a commercial rental property as collateral? Single pay, 12 month note.
Posted By: John Burnett

Re: Earlies needed? - 01/20/15 04:21 PM

Under current rules, no, because the loan would not be subject to RESPA and would not be secured by the consumer's dwelling.

But if an application for such a loan is received on or after August 1, 2015, the consumer purpose and the fact that it would be secured by real estate would make the loan subject to the TILA/RESPA Integrated Disclosures (TRID) rules which call for a Loan Estimate and Closing Disclosures.
Posted By: RR Joker

Re: Earlies needed? - 01/20/15 04:44 PM

Maybe you need to define "commercial rental property' because if it's a dwelling-type rental, it would be subject to disclosure unless it falls in a temporary category.
Posted By: John Burnett

Re: Earlies needed? - 01/20/15 06:58 PM

Good point. I was thinking "commercial rental property" was retail or office space. But of course it could be a 1-4 family dwelling