Loans Not Covered by TRID
Implementation of the Consumer Financial Protection Bureau’s integrated mortgage disclosures is Aug. 1, 2015. Note that there is no stagger in the roll out. All mortgage applications prior to Aug. 1, 2015 will use the current Good Faith Estimate, HUD-1 and Truth-in-Lending disclosures. All applications received on or after Aug. 1, 2015 will use the new Loan Estimate and Closing Disclosure.
The integrated mortgage disclosures apply to most consumer mortgages except:
- Home-equity lines of credit
- Reverse mortgages
- Mortgages secured by a mobile home or dwelling not attached to land
- No-interest second mortgage made for down payment assistance, energy efficiency or foreclosure avoidance
- Loans made by a creditor who makes five or fewer mortgages in a year
Federal law does not require the use of the HUD-1 or the new Closing Disclosure in all-cash transactions. While some states have laws requiring the use of a state promulgated form in cash transactions, in general the HUD-1, the Closing Disclosure or any other settlement statement can be used in cash transactions.
In addition, federally related mortgage loans generally exclude temporary financing and construction loans.