Monthly Payment Loan Disclosures
Monthly Payment Loans require separate disclosures from the first mortgage. Due to the implementation of the TILA/RESPA Integrated Disclosure rule (TRID) on August 1, 2015, the type of disclosure(s) required depends on the borrower’s loan application date.
Loans with application dates prior to August 1, 2015 require a separate:
- Good Faith Estimate
- Initial Truth in Lending
- Final Truth in Lending
Loans with application dates on or after August 1, 2015 require a separate:
- Loan Estimate
- Closing Disclosure
In addition to the required disclosures, Monthly Payment Loans should adhere to all other industry-standard documentation requirements.
For all interest-free, non-amortizing loans such as Deferred Payment and Deferred Payment Plus loans, lenders should consult their compliance departments regarding disclosures and follow industry-standard guidelines, processes, and timelines for these downpayment and closing cost loans.