DPA provider has a product that is forgivable after X years if the home is not sold or the loan is not refinanced in that X year period. 0% interest loan and no payments are due during the term. This seems like a balloon loan product for TRID purposes, but I've not run across this before. Anyone familiar with this type of loan product?

Thanks!

Refer to 1026.03(h) to see if your DPA is exempt from disclosures.

It is not.

Then you would have to read the DPA contract. We have prepared some of these and based the disclosures on the contract as if no forgiveness was being provided, as any forgiveness would be a subsequent event.

Thanks.

Digging this back up again. Unless I'm reading 1026.3(h) and its commentary wrong, and I may be, loans that meet the 6 criteria mentioned in this section only have an exemption regarding the type of disclosures to provide, GFE/TIL or LE/CD and not an exemption from Reg. Z altogether. Please gently correct me if I'm wrong.

Thanks!

Correct: 1. Partial exemption. Section 1026.3(h) exempts certain transactions from the disclosures described in § 1026.19(g), and, under certain circumstances, § 1026.19(e) and (f). Section 1026.3(h) exempts transactions from § 1026.19(e) and (f) if the creditor chooses to provide disclosures described in § 1026.18 that comply with this part pursuant to § 1026.3(h)(6)(i), but does not exempt transactions from § 1026.19(e) and (f) if the creditor chooses to provide disclosures described in § 1026.19(e) and (f) that comply with this part pursuant to § 1026.3(h)(6)(ii). Creditors may provide, at their option, either the disclosures described in § 1026.18 or the disclosures described in § 1026.19(e) and (f). In providing these disclosures, creditors must comply with all provisions of this part relating to those disclosures. Section 1026.3(h) does not exempt transactions from any of the other requirements of this part, to the extent they are applicable. For transactions that would otherwise be subject to § 1026.19(e), (f), and (g), creditors must comply with all other applicable requirements of this part, including the consumer's right to rescind the transaction under § 1026.23, to the extent that provision is applicable.