I cannot think clearly today so asking for some assistance.

Borrower owns primary residence free and clear and wants to refinance. All assets are held through a irrevocable trust, and so the consumer submitted an application in the name of the trust and she will be personally guaranteeing the debt. Reg. Z excludes loans made to non-natural persons, so no TIL disclosures or ROR required. But RESPA does not include the "natural person" exemption, so would RESPA disclosures apply?

The definitions section of HUD's Reg X (3500.2) says, "Person is defined in section 3(5) of RESPA (12 U.S.C. 2602(5))." It drives me nuts when they do that!!

So, following the yellow brick road to the actual Act ( here ), I find: "(5) the term "person" includes individuals, corporations, associations, partnerships, and trusts".

So, since this isn't a business purpose loan, it looks to me like RESPA does indeed apply. Joy!

Thank you Rebekah