Skip to content

Disclosures-CD to Purchase Vacation Home

Question: 
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?
Answer: 

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.

Answer: 

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

Filed under: 
Filed under compliance as: 
Filed under lending as: 

Banker Store View All

From training, policies, forms, and publications, to office products and occasional gifts, it’s available here:

Banker Store

hot right now

image description

Looking for effective, convenient training on a particular subject?

BOL Learning Connect offers more than 200 courses ON-DEMAND or on CD ROM from AML to Reg Z and every topic in between.

Search Topics