Compliance Alliance Q&A 6-11-18
I have a loan for $200,000 to purchase a principal dwelling. It is unsecured. Do I need a TIL, or since it's out of the threshold, is it exempt from the regulations?
Because the loan is not secured by real property and is over the current Regulation Z threshold of $55,800, it is exempt from Regulation Z, meaning no TRID or TIL forms would be required. Additionally, the loan would be exempt from RESPA and HMDA because it is unsecured. Keep in mind, however, that you will still need to abide by safety and soundness concerns, the bank’s underwriting policy, and any other statutory or regulatory concerns that might apply (ECOA/fair lending, FCRA, e-SIGN, state law, etc.)
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