Answer:
Whether the rate spread is NA will depend on the purpose of the loan. The purchase of an investment property is not automatically exempt as a business purpose loan and Reg Z exempts rental property. If I have an opportunity to buy a piece of property for 40% of it's value, renovate it and resale it for a profit then I have made a personal investment, therefore, it is a consumer loan. If I'm in the business of buying, renovating property for resale then that would be a business purpose and exempt. You need to look to 226.3 and its Commentary for guidance.
First published on BankersOnline.com 2/26/07