Answer:
By definition in 226.32(a)(1) the Reg Z HOEPA provisions only apply to consumer credit. If the loan is primarily for business purpose, HOEPA would not apply.
First published on BankersOnline.com 9/10/07
HOEPA & Business Purpose Loans
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Question:
When we make a business purpose loan taking the borrower's primary residence as collateral, are we required to check for HOEPA or can I assume that if a TIL is not required then HOEPA would not apply?
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