Typically it wouldn't, since it was not a FHA or conventional loan.  I would contact a local attorney if there are any legal information that you are looking for.

Voyage Home Loans

Mike Kim

To the best of my knowledge Private Money does not fall under the TIL. Do consult an attorney with specific questions.

Why did go to the Hard Money route in the first place?

You could have taken a HELOC?

If the terms of Hard Money Loan permit, get a HELOC and pay off the Hard Money Loan.

Reg Z is a complicated statute and may or may not apply to this transaction. Some of the things that would need to be considered is what the loan was used for and was the private party a creditor.

If the loan was not for business purposes and the private party regularly lends money it is likely that the TILA would apply.