Yes, the TILA-RESPA integrated disclosure (TRID) disclosure requirements apply to bridge loans, even though bridge loans are exempt from RESPA regulations.

In publishing the final rule implementing TRID, the CFPB acknowledged that temporary loans may have unique characteristics that make them ill-suited for RESPA disclosures. Nevertheless, the CFPB included temporary loans in the TRID disclosure requirements because “covering temporary loans secured by real estate will benefit consumers and facilitate TRID compliance because covering real estate-secured, closed-end consumer credit transactions, other than reverse mortgages, provides a clear compliance rule for industry.”

For resources related to our guidance, please see:

• TRID requirements, Regulation Z, 12 CFR 1026.19(e) and (f) (The TRID requirements apply to any “closed-end consumer credit transaction secured by real property . . . .”)

• Coverage of RESPA, 12 CFR 1024.5(b)(3) (Generally exempting temporary financing and stating that “[a] ‘bridge loan’ or ‘swing loan’ in which a lender takes a security interest in otherwise covered 1- to 4-family residential property is not covered by RESPA and this part.”) 

• Final TRID Rule, 78 Federal Register 79730, 79792 (December 31, 2013) (“The Bureau believes covering temporary loans secured by real estate will benefit consumers and will facilitate compliance because covering real estate-secured, closed-end consumer credit transactions, other than reverse mortgages, provides a clear compliance rule for industry.”)