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HUD Required for 1-4 Res. Homes Used for Rental?

Question: 
Do we have to prepare a HUD for 1-4 res. homes used for rental property?
Answer: 

Kathleen Blanchard

If the loan has been determined to be business purpose, it would not be subject to RESPA and thus no HUD-1 would be required.

Answer: 

Jim Bedsole

Reg Z Section 1026.3(a) provides the exemption for business purpose loans (and RESPA says if it is business purpose for Reg Z it is business purpose for RESPA). In the Official Staff Commentary, the CFPB provides further details about how to make that determination, and specifically in comments #4 and #5 to that section addresses rental property loans.

First published on 02/23/2015

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