I've read a number of posts regarding this subject but am still somewhat confused about what is required. We look at a loan as being construction/perm if we may do the financing. If the applicant asks for a construction loan but there is no takeout from another lender then we assume it will be us that does the permanent loan. However, we are only giving the GFE, TIL, and HUD-1 disclosures for the construction phase at inception. We do the permanent loan disclosures when we do the permanent loan. From reading other posts it seems like we have a timing problem on the disclosures of the permanent phase.

My question is what if the application form only shows a construction loan is being applied for? Are we required to give the PTIL and GFE for the permanent phase within 3 days of the original application for the construction phase since even though it's not on the application we may do the permanent loan?

If you are "approving" the application based on doing both the const and perm loan all early disclosure are due within 3 business day of receipt of that application.

The purpose "stated" on the application holds no water, it's the true purpose of the loan that will be looked at.