Yes, this loan would be treated as a consumer purpose loan under Regulation Z. A consumer purpose loan is one offered or extended “primarily for personal, family, or household purposes.” If a borrower is purchasing a home for a family member and will not be collecting rent, we would view the loan as extended for family purposes, making it a consumer purpose loan.

For resources related to our guidance, please see:

• 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 1026.3(a) (“The following transactions are not subject to this part . . . : (a) Business, commercial, agricultural, or organizational credit. An extension of credit primarily for a business, commercial or agricultural purpose.”)