How do you disclose the TRID loan purpose for a 1-year interest-only loan that then converts to a 5/1 ARM? The rate for the interest-only period is the same as the introductory rate for the ARM. I've read .37(a)(10) but am still confused.

Is it "1 year interest only, 5/1 adjustable rate" or is it "1 year interest only, 6/1 adjustable rate"?

Seems like the first makes the most sense to me...

Totally depends when the first adjustment occurs - year 6 or year 7 - it is all one loan.

It's combined interest only + ARM. Interest-only for the first year - then the ARM kicks in and it's fixed for 5 years. So, if loan was originated 1/1/2020 - it would be interest-only through 1/1/2021 then the first adjustment would be 1/1/2026.

Then it is a 6/1 ARM from a TRID perspective.

That's what I was afraid of - so it's "1 year interest only, 6/1 adjustable rate" - right?

Correct