I'm hoping someone can clarify the exemption provision in the TRID Amendment that was published last July. If a Down Payment Assistance loan meets the partial exemption conditions under 1026.3(h) and 1024.5(d), if the creditor chooses not to utilized the TRID disclosures, does the creditor have to provide an Early and Final TIL, or may they provide a form that conforms with the disclosure requirements under 1026.18 prior to consummation?

Creditors may provide, at their option, either the disclosures described in § 1026.18 or the disclosures described in § 1026.19(e) and (f). In providing these disclosures, creditors must comply with all provisions of this part relating to those disclosures.

There are no early disclosure requirements for 1026.18 disclosures.

Talk about reading too much into something! I was thinking we would go back to the pre-TRID rules whenever a file qualified for the partial exemption.

It's the creditor who provides the down-payment assistance loan fitting the criteria in 1026.3(h) that gets to choose which of the two disclosure regimes it wants to use. That doesn't affect your disclosure responsibilities if you're providing the first-lien loan.