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Reply To: Consumer Loan Disclosed as Commercial

Home Forums Truth in Lending/ Regulation Z Consumer Loan Disclosed as Commercial Reply To: Consumer Loan Disclosed as Commercial

#11753

rcooper
Keymaster

You may have already done this but if you have not, I would very carefully consider whether this is a business or consumer purpose – take a close look at the exemption language in 1026.3 and the details of the transaction. If it is, indeed, a consumer purpose loan you have a violation. I would provide the disclosure, determine the cause for this error (are enhanced procedures necessary, etc.). As you mentioned, training is a must in this situation and a good reminder to lenders is, when in doubt give it out.