I have read a few posts, but I am still struggling to determine if the following scenario would be exempt from HMDA and HPML initially or not.
I have a consumer purpose residential loan where the funds will be used to purchase land and a double wide mobile home. The loan is a closed end loan, but the borrowers are making draws and has only drawn around $12,000 to purchase the land. The double wide has not been purchased yet. The loan application notes the purpose of the loan as both the "purchase" and "construction" of the borrower's primary residence. I assume the officer marked construction since the dwelling is a double wide and will require some work before the borrowers can live in it. Also, the term of the loan is only for 9 months, again I assume this is b/c of the "construction" part. Should this loan be included on the LAR as a purchase now and HPML requirements followed or should it be treated as a temp. loan (loan will be replaced by loan of longer term later) and include it as a purchase and HPML when the loan is put on the longer term?

Usually there are set-up expenses and preparation for these loans and we treat them as a 2 phase const/perm loan. We treat the first phase as temporary financing and we don't report until it converts to permanent financing.

Thank you for your help.