Answer by David Dickinson: If I understand you correctly, the bank will be making a loan to a consumer on leased land. The bank will not have a security interest in the land - just the dwelling. If so, then RESPA does not apply as the loan is not secured by real estate.
Answer by Dan Persfull: David is reading it as leased land and his answer based on his interpretation is accurate. I'm reading it as OREO property for the bank and an applicant is applying to purchase the property. If my interpretation is the correct one then RESPA does apply if it is a consumer purpose loan.
First published on BankersOnline.com 11/14/11