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The CFPB has issued a fact sheet clarifying that, in most cases, construction loans are subject to the Loan Estimate and Closing Disclosure requirements of TRID. Exceptions to the rule include open-ended transactions and commercial loans. There are two points of interest for lenders:
Construction to Permanent Financing: The Fact Sheet reminds lenders that they have the option to treat the construction phase and permanent phase as either one transaction or more than one transaction for purposes of the required disclosures. The lender has the option to provide a combined disclosure or separate disclosures. This election exists regardless of whether the construction and permanent phases close at the same time or separately.
Multiple Advance Loans: The Fact Sheet also reminds lenders that Appendix D to Regulation Z provides a procedure to estimate and disclose the terms of construction loans with multiple advances. The Fact Sheet calls special attention to Comment 7 which “provides guidance for making the projected payments disclosures for construction loans in the Loan Estimate and Closing Disclosure.”
Caren Enloe is a partner who concentrates her practice in consumer financial services litigation and compliance, bankruptcy, and commercial litigation with an emphasis on creditor’s rights. She has a deep understanding of the complex compliance environment surrounding the financial services industry and regularly advises financial service companies on licensing and compliance issues involving state and federal consumer protection and finance statutes. Caren is the author of a daily blog titled: Consumer Financial Services Litigation and Compliance where she posts timely and informative updates regarding the CFPB, FTC, and a host of topical litigation issues involving consumer protection law....LEARN MORE