The product can be described as "11 mo. Interest Only Fixed Rate" (if, of course, the rate won't change during the construction loan term). [Reg D comment 7.ii.A.]
You answer "YES" as the answer to "Can this amount increase after closing?"
You will show the single payment amount calculated as the monthly payment for one-half of the loan amount at the applicable interest rate.
Then in the bullet items explaining the YES answer, you say
- Adjusts ever mo. starting in mo. 1
- Can go as high as $[max periodic P&I payment -- in this case interest payment] in year 1. You base this number on the max possible balance that could be outstanding in the construction phase. [comment AppD-7.iv.B.]
- Includes only interest and no principal
- See AP Table on page 2 for details
Yes, you will have an AP table under the rules with a mandatory compliance date of 10/1/18.
In that AP table you will complete it as an interest only loan, omitting the First Change/Amount dollar amount or range, but indicating "at 1st payment". You'll insert "Every month" to the right of "Subsequent Changes" and the maximum payment amount will be the same as the maximum interest payment disclosed ("Can go as high as $ _________") disclosed on page 1.