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RESPA Apply to Loan if Also Executing a Mortgage?

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Question: 
I have a loan request for the purchase of residential real estate by a child of a good bank customer. The bank customer will secure the loan with a certificate of deposit, but also wants the bank to execute a mortgage on the real estate. The bank customer will also guarantee the debt. The child is just starting a job and will not qualify for a traditional mortgage at this time. The loan term will be for one year, interest only payments. The goal is that the child will be able to refinance to a traditional mortgage at the end of the loan term. I know this loan is HMDA reportable, but is RESPA applicable, (because we are also executing a mortgage)?
Answer: 

Yes, RESPA and TIL would apply.

First published on BankersOnline.com 5/7/12

First published on 05/07/2012

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