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Disclosures-CD to Purchase Vacation Home

I have a borrower who is using a CD as security for a loan to purchase a vacation home. What if any disclosures are needed?

by Jim Bedsole:

Assuming it's not secured in any way by the real estate, then TRID rules would not apply. However, because it is a vacation home, not a rental home, it would still be consumer purpose. So the standard TIL disclosure would be required.


by Randy Carey:

Minor clarification: The standard TIL disclosure would be required if the loan amount was not over the current 2015 and 2016 Regulation Z threshold of $54,600

First published on 12/06/2015

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