IMO, I say no.
Are you planning on being the lender that originates the loan for the customer throught the secondary market for perm financing? If yes, then you’ll need to do RESPA.
Re: RESPA exemption
IMO, I say no.
Are you planning on being the lender that originates the loan for the customer throught the secondary market for perm financing? If yes, then you’ll need to do RESPA.