TRID for Construction Loans

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    Good Afternoon, I attended the TRID for Construction Loans webinar on March 20th. We are not currently originating Construction-to-Permanent loans but are looking into the compliance ramifications of these loans. I have a couple of questions regarding construction-to-permanent loan.

    When is the ARM disclosure given to customers regarding the first rate change on Construction-to-Perm loans? For example, we disclose both phases on one LE the 12 month construction phase will have its own rate (int. only) and the permanent phase will have a different rate (ARM product). The LE will show the interest rate of the construction phase. When are we required to send the subsequent disclosure notifying the customer of the first ARM rate change?

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