Yes, the new Loan Estimate is required for every “closed-end consumer credit transaction secured by real property,” including bridge loans.

Property: The Loan Estimate should list both property addresses, because both properties secure the transaction. The Official Interpretations to Regulation Z state that “where more than one property secures the credit transaction, § 1026.37(a)(6) requires disclosure of all properties.”

Value: We believe that you should separately disclose the value of both properties, although the Official Interpretations are silent on disclosing property values for loans secured by multiple properties. Regulation Z requires you to provide a sales price for transactions that involve a seller and a property estimate for transactions that do not involve a seller, without addressing loans secured by multiple properties. However, because the Official Interpretation referenced above requires you to disclose multiple property addresses, we believe the most logical solution would be to also disclose multiple property values — the sales price for the purchased property and an estimated value for the borrowers’ current residence.

Purpose: We believe the loan purpose should be labeled as a “purchase,” because the loan will finance the purchase of one of the properties securing the credit. Again, the rule and the Official Interpretations do not squarely address a bridge loan secured by multiple properties, but the most logical choice among the options (Purchase, Refinance, Construction or Home Equity Loan) is to label the loan purpose as a purchase.

Product: The loan product should be described as “11 mo. Interest Only, Fixed Rate.” The first part of the description, “11 mo. Interest Only,” is a disclosure of the primary loan feature, with the “applicable time period” of 11 months (disclosed as “11 mo.” under the Official Interpretations). The second part of the description, “Fixed Rate,” reflects the type of interest rate.

For resources related to our guidance, please see:

• Regulation Z, 12 CFR 1026.19(e)(1) (“In a closed-end consumer credit transaction secured by real property, other than a reverse mortgage subject to § 1026.33, the creditor shall provide the consumer with good faith estimates of the disclosures in § 1026.37 [the Loan Estimate].”)

• Regulation Z, Official Interpretations, 12 CFR 1026, Paragraph 37(a)(6), Comment 2 (“Where more than one property secures the credit transaction, § 1026.37(a)(6) requires disclosure of all properties. If the addresses of all properties securing the transaction do not fit in the space allocated on the Loan Estimate, an additional page with that information with respect to real properties may be appended to the end of the form.”)

• Regulation Z, 12 CFR 1026.37(a)(7) (“Sale Price. i. For transactions that involve a seller, the contract sale price of the property identified in paragraph (a)(6) of this section, labeled ‘Sale Price.’ ii. For transactions that do not involve a seller, the estimate value of the property identified in paragraph (a)(6), labeled ‘Prop. Value.’”)

• Regulation Z, 12 CFR 1026.37(a)(9)(i) (“If the credit is to finance the acquisition of the property identified in paragraph (a)(6) of this section, the creditor shall disclose that the loan is for a ‘Purchase.’”)

• Regulation Z, 12 CFR 1026.37(a)(10) (This subsection provides very specific instructions for the product description, which must include the primary loan feature, with its “applicable time period,” and the type of interest rate.)

• Regulation Z, Official Interpretations, 12 CFR 1026, Paragraph 37(a)(10), Comment 2(ii) (“When disclosing an ‘Interest Only’ feature . . . the applicable time period must precede the label ‘Interest Only.’”)