Would a 9 mo interest-only home improvement loan that is going to be made fixed after the 9 mos Short term financing? If so or if not is it subject to RESPA and TIL?

What about HMDA?

It is on the borrower's primary dwelling and it is partly a refinance of a mortgage from a different bank and new money for the home improvement.

OK so I have been researching and there have been answers to similar questions but it seems as though some of them contradict. What I understand now is that this is temporary financing. Temporary Financing is not covered by RESPA or HMDA. However, I have found guidance that says the opposite. This is not a new construction. Anyone??

Temporary financing, financing primarily designed to be replaced by longer term financing is exempt from RESPA and HMDA.

However you say the loan is going to be made "fixed" after the 9 month term. How will this be accomplished? New note? Modification?

New note - your 9 month loan is temporary.

Modification - your 9 month loan is the permanent financing with set terms. Not temporary IMO.

Thank you Dan, it will be accomplished with a new note. What about RESPA mentioning that the exemption does not apply if the bank intends on doing the permenant financing? Is that only appicable for a straight-up construction loan?

The exemption for temporary financing does not apply to a loan made to finance construction of 1- to 4-family residential property if the loan is used as, or may be converted to, permanent financing by the same lender or is used to finance transfer of title to the first user. . . .

This only applies to the initial construction loan. Renovation/HI loans would not be considered construction loans.