If we make a construction loan that we may convert to perm financing when do we do the RESPA disclosures for the second loan.

Do we do the RESPA disclosure for the construction loan initially and then at the end of the construction loan term we disclose for the perm loan?

Both disclosures are due within 3 business days of the application for the const (const/perm) request.

Be sure you take advantage of the 60 day redisclosure clause for the GFE for the perm. (3500.7(f))

That suggestion about the 60-day redisclosure clause is very helpful, Dan. In fact, one of our lenders had asked me this morning about whether he needed to provide new disclosures for the permanent financing phase of the debt obligation following construction. He had given the GFE, ETIL, etc. to the customers following their application in regards to the initial 12-month construction loan request, since they were unsure about whether they would remain with our bank for the permanent financing.

Our lenders acutally originate two separate loans, as opposed to one loan agreement with a clearly defined construction period, whereby interest payments are made, then eventually rolling over into a permanent phase with regular monthly installments thereafter. Now he has scheduled the customers to return and sign the paper-work for the permanent financing of the debt, without giving any early disclosures this time around. Sadly, the 60-day disclosure notice had never been provided to the customers either... though I recommended that he do this in the future. I also suggested that he call them as soon as possible and re-schedule the closing.

Rather than enter into a lengthy discussion, I just sent an e-mail to him containing an earlier thread where you have addressed this topic. I could not explain the topic any better than you have already. Seems to me this issue is creating alot of confusion among lenders.