If a customer gets an unsecured bridge loan to purchase their primary residence, then refinances the loan for permanent financing (secured by the dwelling) would we collect monitoring information? The purpose for TRID will be home equity because the loan that is being paid off is not secured by the dwelling, but the unsecured loan that is being paid was to purchase their primary residence.
1002.13(a) Information to be requested. (1) A creditor that receives an application for credit primarily for the purchase or refinancing of a dwelling occupied or to be occupied by the applicant as a principal residence, where the extension of credit will be secured by the dwelling, shall request as part of the application the following information regarding the applicant(s)…
It needs to meet three criteria:
1) it is a refinancing of a dwelling (even though it wasn’t secured by the dwelling, the original loan was to finance the purchase of the dwelling)
2) it is/will be the applicant’s principal residence (I assume this is the case)
3) it will be secured by the dwelling (you stated the refinance will be secured by the dwelling)
As I noted above, it seems you meet the criteria for collecting monitoring information as stated above in 1002.13.
I just want to make sure I understand, to be considered a refinance (per Reg B) it does not have to be a dwelling-secured debt obligation that satisfies and replaces an existing, dwelling-secured debt obligation by the same borrower.