Home Construction Secured Only By Investment Acct.

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Question:

Our borrower wants a new home construction loan that will be secured only by an investment account. It is for a home he will live in once completed. What, if any, TIL or other disclosures must the bank provide since there is no actual dwelling or dirt securing the loan?

Answer:

Since the loan is not secured by real property, if the loan is over $54,600, it will be exempt from all provisions of Regulation Z.