The type or property is not a determining factor as to if the new rule is applicable to the transaction. The new rule applies to a closed-end consumer credit transaction secured by real property, other than a reverse mortgage, HELOC, mortgages secured by a mobile home or by a dwelling that is not attached to real property.
Loan Estimate – integrates the GFE and Initial TIL Closing Disclosure – integrates the final TIL and HUD-1
25+ acre loans were exempt from RESPA under Regulation X and were only covered by TILA if the loan purpose was for personal, family or household use. Under the new rule, effective August 1st, 2015, the RESPA exemption has been removed pursuant to Regulation X and now the two regulations are consistent. If the loan proceeds are for personal, family or household use, the transaction
Consumer credit means credit offered or extended to a consumer primarily for personal, family or household purposes.