I have a loan officer that is doing a loan and they are only taking the land as collateral. The borrower does live on the property in a camper. We are not taking the camper has collateral. Will there be a Right of Rescission? I’m thinking that I will need to do a ROR. r
Will any of the other 1-4 family disclosures apply? Just as notice to home owners, counseling disclosures and also the Acknowledge of Receipt of Appraisal.
I confused on this one.
Each aspect of your question is addressed separately below:
• Right of Rescission – Since your loan does not include a security interest in the principal dwelling, the right to rescind does not apply.
• Notice to Home Owner – Please clarify which disclosure you are referring to.
• Counseling Disclosure – Required by RESPA, which only applies to loans secured by 1- to 4-family dwelling and land. You don’t have the 1- to 4-family dwelling.
• Acknowledge of Receipt of Appraisal
o Regulation B – A creditor shall provide an applicant a copy of all appraisals and other written valuations developed in connection with an application for credit that is to be secured by a first lien on a dwelling. Your loan is not secured by a dwelling.
o Regulation Z – HPML – A HPML must be secured by the consumer’s principal dwelling. Your loan is not secured by a dwelling.
PS: I apologize for the slow reply. I had website access issues today.