CFPB TRID Sec. 4 - Are trusts for estate or tax planning purposes considered consumers under Regulation Z so as to be covered by the TILA-RESPA Rule?

Compliance > Regulation Z - TILA / TRID Specific > General Info
Q:  Are trusts for estate or tax planning purposes considered consumers under Regulation Z so as to be covered by the TILA-RESPA Rule?
 
A:  When disclosing the name of the consumer on the Loan Estimate for a trust, the creditor may opt to disclose the name and mailing address of the trust only, although nothing prohibits the creditor from additionally disclosing the names of the trustee or of other consumers applying for the credit. Further, on both the Loan Estimate and the Closing Disclosure, a creditor may include a signature line and insert the trustee’s name below, along with a designation that the trustee is serving in its capacity as a trustee. (Comment 37(a)(5)-1) See the TILA-RESPA Guide to Forms for more information about disclosing the consumer’s name and use of signature lines.
 
 
This can be found in the CFPB's TILA-RESPA Integrated Disclosure rule compliance guide - http://www.consumerfinance.gov/regulatory-implementation/tila-respa/
 

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