Answer:
Dan Persfull: If secured by personal property where the loan amount is less than $50,000 the threshold is 8.5% vs 6.5%. Loans secured by personal property where the loan amount is $50,000 or more are subject to the 6.5% threshold.
I see no reference in the guidance where loans secured by personal property with a loan amount of $50,000 or more are exempt.
Answer:
Kathleen Blanchard: If the loan is not secured by land, is over the Reg Z threshold, and is not secured by personal property to be used as consumer's principal residence, the loan would be exempt from Z overall. Otherwise, all requirements apply.
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