Temporary Construction Loan - Does HMDA Apply?
Answer by Dan Persfull, BOL Guru Guru Bios
Question: We are making a temporary construction loan to build a new residence which we have as collateral and part of the proceeds will be used to pay off the debtor's current dwelling which we will also have for collateral. Is this considered new construction and not HMDA reportable or a refinance and reportable?
Answer: HMDA would not apply. However Reg Z's right to rescind would.
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