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#2281846 - 03/03/23 04:49 PM Construction to Perm ; different rates
newyork Offline
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Joined: Aug 2008
Posts: 452
Hello. Is a construction to perm primary residence loan allowed to have two different rates under TRID rules? For example, during the construction phase a fixed rate and during the permanent phase an adjustable rate (ARMS)?

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TRID - TILA/RESPA Integrated Disclosures Rule
#2281848 - 03/03/23 04:53 PM Re: Construction to Perm ; different rates newyork
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 83,370
Galveston, TX
TRID has nothing to do with pricing your loans. TRID is a disclosure regulation. You design your products based on State law, then you figure out how to disclose them..
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#2281875 - 03/06/23 12:55 AM Re: Construction to Perm ; different rates rlcarey
Richard Insley Offline
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Richard Insley
Joined: Oct 2000
Posts: 10,180
Toano, VA
Originally Posted by rlcarey
design...then...disclose
Yes, however...there will be those cases where the design must be changed due to the difficulty or cost of preparing appropriate disclosures. This is why it's so important for a regulatory compliance officer to be included in all loan product development task forces, committees, or other discussion groups. The sooner regulatory complications are ID'd, the longer you have to find an affordable work-around.
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...gone fishing.

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