[Sandy]

This may be a silly question. We are having some of our TRID loans show up as Deep Discount now. We are a non escrow Bank. We typically prepare the borrower’s note with their payment due 30 days from closing. I understand that with these Deep discount loans the payment is due at the first of the month. In our TRID training when TRID began in 2015/2016 it stated in the training that interest needed to be collected thru the 1st (when payment is due the 1st) and shown on the LE or the CD. Does this only apply to Banks that do escrow?

[jholzknecht]

It appears that the term “deep discount” has a special meaning to you. The term is not used in TRID. I am not aware of a TRID provision that requires interest to be collected thru the 1st, when payment is due the 1st. Other section os Regulation Z establish rules for collections of payments.

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