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Currently, the rules are focused on Consumer lending. However, I would not forget that Small Business tends to follow the lead of consumer. With 1071 rules going into play, you may want to consider any loans that will use personal property as collateral falling into these rules.
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So would you consider a second home, not otherwise used for commercial purposes, to be personal property and included in these rules? I am thinking Yes, but I really hate to make this even more complicated for our commercial lenders.
Yes, I would consider a second home to be included in the rules. I’m more prone to be conservative when it comes to consumer protection.
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