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The following loans are not affected by the updated Truth in Lending laws:
Home Equity Lines of Credit (HELOCs)
Mortgages secured by a mobile home or dwelling not attached to real property
So if the loans are such as above, then TRID does not apply.
Regulation Z applies to businesses or persons who are known as creditors. A creditor is defined as one who: regularly extends consumer credit that is either subject to a finance charge or is payable in more than four installments. A person regularly extends consumer credit only if it extended credit more than 25 times (or more than 5 times for transactions secured by a dwelling) in the preceding calendar year.
Also, all real estate lending transactions involving consumers are covered by Regulation Z. Except for real estate transactions, any credit transactions extended in five or more installments and not in excess of $25,000 for personal, family, household or agricultural purposes are covered.
Reference - see 12 C.F.R. 226 HERE.
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