CFPB TRID Sec. 14.21 - How is the “In 5 Years” amount calculated when the construction phase is disclosed as a separate transaction and its term is 12 months or less?

Compliance > Regulation Z - TILA / TRID Specific > General Info
Q:  How is the “In 5 Years” amount calculated when the construction phase is disclosed as a separate transaction and its term is 12 months or less?
 
A:  When the construction phase of a construction-permanent loan is disclosed as a separate transaction and is less than 60 months in duration, as it typically is, the creditor discloses the amounts paid through the end of the loan term in the Total of Payments table. The amount disclosed would be the full amount of the total principal, interest, mortgage insurance, and loan costs scheduled to be paid through the end of the construction phase. (Comment 37(l)(1)-1)
 
 
This information 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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