I am moving this question to a new subject since I originally posted it under "bridge loans" but the question for consideration is more broad.

I believe the regualtion is clear about what the purpose of the loan is for the sake of disclosure on the LE. Purchase - when the property being acquired is also the collateral.

I am struggling however, when determining when other seller related information must be provided.

For example the following pieces of information are required when the transaction involves a seller.

*other costs related to the purchase transaction 37(g)(4), *transaction information for the seller 38(a)(4)(ii),
*sale price 37(a)(7)(ii),
*borrower and seller transaction information in 38(j)-(k), *seller credits 37(h)(1)(vi)

In a payoff C4D situation, must we provide seller information for the disclosure requirements listed above? Do we need to capture other costs associated with the payoff C4D to ensure they are disclosed in 37(g)(4)? Does the seller's name get listed on the Closing disclosure? Are there required disclosures under 38(k)? Do we need to concern ourselves with any possible seller credits?

For a temporary bridge loan where the loan is not secured by the property being purchased, the loan purpose to disclose on the LE is not "purchase" however it appears that there is a seller involved because the loan proceeds will be used by the borrower to purchase another home. Do all of the seller related disclosures referenced above apply? Is the answer dependent on whether we will effectuate the transfer as part of the transaction?

For a home equity loan where equity in the borrower's current home is used to purchase a second home (which does not secure the loan), do all of the seller related disclosures apply?

Piggyback - jr lien loan is secured by same property being purchased, do all of the seller related disclosures apply?

Today, other than the contract for deed situation, we do not provide the seller info on disclosures. The loan is closed as a cash out refinance and the borrower separately uses the funds to purchase the property with cash. I'm wondering if our approach to disclosure of seller info will need to change.

Thank you once again to those of you who have reviewed my series of questions this morning.

First, I have no idea what a C4D is????

Let's address a piggy back loan first. The answer is no to the seller disclosures and the CFPB directly opined on that in the August 26th webinar:

"Therefore, a creditor may use the alternative Loan Estimate for transactions without a seller for closed-end simultaneous seconds but is not required to do so."

As for the other examples (other than the C4D), they are all home equity loans. There is no seller in these loan transactions. The borrower gets the money and whether they spend it on a vacation or they ask you to wire it to a title company to buy another piece of property, it does not impact the fact that there is no seller in the transaction.

HMDA reporting would be considered differently under the HMDA rules, but that does not impact the TRID disclosures.

I figured out late last night C4D is contract for deed (saw another post by same individual).

Yes, I am so sorry about the C4D reference -- I can't tell you enough how much I appreciate your help.

Circling back -- if our loan will be used to payoff a contract for deed, do you think we are required to disclose seller information? Would you list the purpose as a purchase?

Good question and I don't think there is an answer. You might have to draw some parallels to another part of Regulation Z - specifically the definition of an residential mortgage transaction: "Acquisition: The term does not include a transaction involving a consumer's principal dwelling if the consumer had previously purchased and acquired some interest to the dwelling, even though the consumer had not acquired full legal title."

But you could probably handle either as a purchase or a refinance from a TRID perspective and I don't think anyone could specifically fault you.

Thank you once again Randy.