We believe that neither RESPA nor Regulation Z would apply to the loan to purchase a rental property that would not be owner-occupied. RESPA excludes from coverage any loan made “primarily for a business, commercial, or agricultural purpose, as defined by” Regulation Z. 12 CFR 1024.5(b)(2). As you noted, Regulation Z does not apply to a loan to buy rental properties: “credit extended to acquire, improve, or maintain rental property (regardless of the number of housing units) that is not owner-occupied is deemed to be for business purposes.” Official Interpretations, 12 CFR 1026, Paragraph 3(a), Comment 4. Because Regulation Z deems loans to buy rental property to be business purpose credit, and RESPA applies the same standards for determining whether a loan is for a business purpose, we believe that this loan is also exempt from RESPA coverage.