Additional guidance related to disclosing construction and construction-permanent loans under federal lending and real estate disclosure rules was released Wednesday by the federal consumer financial protection agency.
The Consumer Financial Protection Bureau (CFPB) said it published two guides to the construction loans disclosures under the TILA-RESPA Integrated Disclosure (TRID) Rule. One (the “combined guide”) provides guidance for disclosing the loan phases together. The other (the “separate guide”) provides guidance for disclosing the phases separately, the bureau said.
“The Construction Guides are not a complete review of the TRID Rule, but instead highlight particular sections of the disclosures based on the questions received by the Bureau,” the agency said of the combined guide. “At the end of this Guide, there is more information about the TRID Rule and related implementation support from the Bureau that can support any of the other pieces not addressed by these guides.”
The bureau noted that two concepts affect how the TRID Rule applies to construction loans. The first, CFPB said, is whether the creditor chooses to use combined disclosures, as discussed in this Guide, or separate disclosures, as discussed in the Companion Guide. The second is whether the creditor chooses to use Appendix D to Regulation Z to estimate certain disclosures, the agency said.