We have been presented with a consumer purpose application (purchase of a home) which will be secured by a commercial property as an abundance of caution. There will be no other collateral attached to this loan. Does TRID apply to this request?

Consumer loan plus DIRT = TRID - it doesn't matter the flavor of the DIRT

If you will be taking a security interest in the property (i.e. deed) then the loan will be covered by TRID. The only place abundance of caution comes into play from a regulatory perspective is the appraisal requirements (FIRREA).

Thank you all!

which will be secured by a commercial property as an abundance of caution. There will be no other collateral attached to this loan.

If the commercial property is the only collateral securing the home purchase then how is it an abundance of caution property? Has it been documented this borrower qualifies for the loan unsecured?

I have a same kind of the same situation. Loan is to purchase primary however, we are taking a different property as collateral. on our purpose would it still be consider a "purchase" for LE?

No, it would be Home Equity as the property taken for collateral is not the property being purchased.

1026.37(a)(9) Purpose. The consumer's intended use for the credit, labeled “Purpose,” using one of the following terms:

(i) Purchase. If the credit is to finance the acquisition of the property identified in paragraph (a)(6) of this section, the creditor shall disclose that the loan is for a “Purchase.”

Thank you, so as far the the "sales price" on the LE we would indicate the value of the collateral of the loan not the collateral being purchased correct?

Since there's no seller involved in your transaction, it should refer to "property value" instead of "sales price", but yes, it will indicate the value of the collateral.

Ok so customer complete RE loan application and indicated purchase primary, but since the collateral securing the loan is vacant land then we do not need GMI correct? Or since the true purpose is to purchase primary do we need?

You should not collect GMI.