We have a "Home Equity Loan", i put it in quotes because it does not mirror a typical loan having a fixed rate, payment and term for the life of the loan. It is a 10 year product amortized over 30 years with a baloon at the 10 year mark. The rate is fixed for 5 years. After that the payment is indexed to prime plus a margin. This seems like a LOC with a long intro rate to me so i am wondering if it should be subject to TRID.

Does the loan meet the definition of open-end credit as defined in Regulation Z § 1026.2(a)(20)? There are three criteria:

(i) The creditor reasonably contemplates repeated transactions;

(ii) The creditor may impose a finance charge from time to time on an outstanding unpaid balance; and

(iii) The amount of credit that may be extended to the consumer during the term of the plan (up to any limit set by the creditor) is generally made available to the extent that any outstanding balance is repaid.

If it doesn't meet those criteria, it's not open-end credit. By default it becomes closed-end credit, and TRID rules apply.