TRID property addresses for multiple property loan

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Question:

Our institution does bridge loans where we take both the property being purchased and the borrower’s current primary residence as collateral. Both properties get listed on the Note and Mortgage. These are treated as a purchase. Do we need to disclose both addresses for this type of transaction on the LE and CD, or would that only be the case if they were refinancing multiple properties or purchasing multiple properties in one transaction? Would the fact that they are purchasing a new home using the equity in the current home that will be sold make it so we would not have to disclose both addresses and only the property being purchased? Currently, I think we would have to disclose both, but want to ensure I am interpreting comments 1026.37(a)(6)-3 and 1026.38(a)(3)(vi)-2 correctly.

Answer:

The wording of the two official interpretations paragraphs you cited is very clear. You are correct in thinking that you disclose both property addresses. The loan purpose (purchase of new property secured by an existing property and by the property being purchased) is irrelevant.

Your question is a great illustration of why an understanding of Regulation Z (and many other regulations) must include an understanding of the official interpretations or staff commentary to be complete.