New TRID Regs Placing Lot Loans under Reg Z

Answered by:

Question:

With the new TRID regulations from October 3, now placing lot loans under Regulation Z, in the event of refinancing a lot loan, does the right of rescission apply?

Answer:

Consumer purpose lot loans were always covered by Regulation Z, but not by RESPA. The change is that these loans now must be documented on the integrated disclosure forms (TRID disclosures).

Rescission applies only to consumer purpose loans that are secured by a customer's principal dwelling (see 1026.23 for closed end rescission rules.) A loan secured solely by unimproved land would not be subject to rescission.