No, the TRID rules do not apply to loans made to business entities. The TRID rules (and Regulation Z generally) apply only to consumer credit transactions, meaning loans offered to a consumer for personal, family or household purposes. A loan extended to a business entity, such as an LLC, is exempt.

However, you may have to comply with the RESPA disclosure rules in Regulation X. Because this loan’s purpose is to buy a personal residence, the Regulation X exemption for business-purpose loans would not apply. Unless another Regulation X exception applies (such as the temporary financing exception), this loan will be subject to RESPA and Regulation X’s disclosure requirements.

For resources related to our guidance, please see:

• Regulation Z, 12 CFR 1026.19(e)(1) and (f)(1)  (The TRID Loan Estimate and Closing Disclosure requirements apply only to consumers in a “closed-end consumer credit transaction secured by real property . . . .”)

• Regulation Z, 12 CFR 1026.2(a)(12) (“Consumer credit means credit offered or extended to a consumer primarily for personal, family, or household purposes.”)

• Regulation Z, 12 CFR 1026.2(a)(11) (“Consumer means a cardholder or natural person to whom consumer credit is offered or extended. . . .”)

• Regulation Z, 12 CFR 1026.3(a)(2) (Regulation Z does not apply to “an extension of credit to other than a natural person . . . .”)

• Regulation X, 12 CFR 1024.5 (“Coverage of RESPA. . . . Exemptions. . . . (b)(2) Business purpose loans. An extension of credit primarily for a business, commercial, or agricultural purpose, as defined by 12 CFR 1026.3(a)(1) of Regulation Z. Persons may rely on Regulation Z in determining whether the exemption applies.”)

• Regulation X, 12 CFR 1024.2(b) (Federally related mortgage loan means: (1) Any loan (other than temporary financing, such as a construction loan): (i) That is secured by a first or subordinate lien on residential real property, including a refinancing of any secured loan on residential real property . . . .”)