Recently an attorney used a CD for a TRID exempt commercial transaction. Although the loan is exempt from TRID, it seems more and more attorneys are migrating from the old HUD and using CDs instead. In this case, no LE was issued as well. So, although commercial loans are generally exempt from TRID, does that mean CDs are prohibited from being issued by third parties to customers?

4.3 Does a creditor have an option to use the new Integrated Disclosure forms for a transaction not covered by the TILA-RESPA Rule?

Creditors are not prohibited from using the Integrated Disclosure forms on loans that are not covered by the TILA-RESPA Rule. (e.g., mortgages associated with housing assistance loan programs for low- and moderate-income consumers). (See §§ 1026.3(h) and 1024.5(d)(2)). However, a creditor cannot use the Integrated Disclosure forms instead of the GFE, HUD-1, and Truth-in-Lending forms for transactions that are covered by TILA or RESPA that require those disclosures (e.g., reverse mortgages).