Under TRID 2.0, how are loans that have refinancing and is also a construction loan be disclosed. I understand the loan purpose is Refinance. But, how should the adjustable payment table be treated.
The Loan Product is an 11 month Interest only, fixed rate.
The Final payment is the balloon payment.
Example. Loan is $500,000. Construction cost is $200,000. Also, we are paying off a mortgage lien on the subject property for $100,000 (refinancing).
For the AP table, can we still leave the payment range blank in the "First Change/Amount" row? Or must we disclose the minimum of the payment range based on the $100,000 disbursement which is being drawn at closing to payoff the lien and then have the maximum based on the full $500,000.
Also, because the loan includes refinancing, the TIP calculates based on the full loan amount?