You need to look at the collateral taken as being security when you prepare your disclosures. For example, the original loan is $50,000 for personal purposes. If not secured by RE would be exempt from Reg Z, RESPA, Flood, etc. Not we add on the RE as an abundance of caution. Reg Z, RESPA and Flood now apply. Lenders have a problem with this type loan because they think it isn't really secured by the extra collateral. Sometimes they say, we aren't even recording the mortgage, but that doesn't matter, it's still secured.