If you work with loans subject to TRID, you know that getting the disclosures right can be complicated. If you deal with construction loans, it can get a lot more complicated. Many construction loans are set up as multiple-advance, closed-end loans, and that bring Appendix D of Regulation Z to the table.
Jerod explains more in the video.
Video Highlights:
- Disclosing construction loans under TRID can be quite complex and confusing.
- One issue when disclosing construction loans is not knowing when the advances are going to be made.
- Appendix D requires lenders to decide how they want to disclose by either assuming half the commitment is outstanding for the entire term of the loan or having interest accrue on 100% of loan proceeds over the term.
Published
2023/07/17