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#2300688 - 08/19/24 09:20 PM Consumer Purpose Loan to LLC - No Tolerance Cure
Wonderofitall Offline
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Wonderofitall
Joined: Sep 2010
Posts: 227
Out West
Consumer RE loan made to an LLC, and RESPA disclosure requirements were made using TRID disclosures. Because Reg. Z doesn't apply to an LLC, do TRID tolerance and Reg. Z APR/Finance Charge rules apply?
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Lending Compliance
#2300693 - 08/20/24 11:15 AM Re: Consumer Purpose Loan to LLC - No Tolerance Cure Wonderofitall
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 85,256
Galveston, TX
I guess one would have to ask how a bank makes a consumer loan to an LLC? If the loan is not for a business purpose, why is the LLC borrowing money and getting approved for such a purpose. But that is just a question.

If you truly believe that you are making a consumer loan to an LLC, it would be subject to RESPA. RESPA has its own rules on tolerance requirements between the GFE and HUD-1. No parts of Regulation Z will apply.
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