We have a construction/perm loan for which 2 GFEs were prepared, one for each phase. Each have duplicate fees listed for things like origination fee, credit report, title services, etc. Is this allowed or should there be a separation of fees between the two phases? I'm looking for some guidance on this as well to support the position one way or the other.

Are you charging these fees twice? If not, list them on 1 GFE, but not both.

off the fee subject.

Is escrow required at time of contruction if you are doing perm. loan?

if so would you complete the escrow section on both GFE's? one for construction phase and one for perm phase?

As bank policy, we do not collect escrow during construction so the escrow section of the construction GFE would always reflect zero. However, the perm loan would be subject to escrow so we disclose for escrow on the perm GFE.

so if we provide two set of RESPA Documents would we just estimate the amounts on the permanent phase RESPA Docs since the amounts could change like the Homeowners Insurance and the Taxes when house is done?

another Question since we will provide RESPA docs on the permanent phase now we would not have to provide them when construction loan is converted to permanent?

Our bank policy is to finance the perm if we finance the construction so we are obligated by RESPA to disclose on both loans within 3 days of application. If you provide the "60 Day Notice" with the initial disclosures you have up to 60 days prior to the closing of the perm loan to change anything you need to on the GFE. We would estimate taxes and insurance like on any loan and would not redisclose later for a change to the escrow figures as RESPA doesn't require it.

we rarely do 1-4 family construction loans what exactly is the 60 day letter?

FAQ page 21, GFE - New Contruction

does any one have a sample of the 60 day letter they are willing to share

Exhibit A to Good Faith Estimate
For NEW CONSTRUCTION


NOTICE TO BORROWER REGARDING GOOD FAITH ESTIMATES AND NEW CONSTRUCTION

This notice is to advise you that we anticipate the closing of your permanent mortgage to exceed 60 calendar days from the date of this Good Faith Estimate. We may issue a revised Good Faith Estimate at any time up until 60 days prior to closing.

(Most platform systems have this notice (or similar) available..you might check your library?

Same topic, slightly different question.... One close construction loan. Construction period of 12 months and then it converts to a 30 year fixed loan. Auditor says to issue only one GFE/TIL. When we incorporate the construction interest for the 12 month period into the GFE/TIL, the loan fails the APOR test. I understand that short term loans are not subject to APOR testing. Are we supposed to be including that interest on the TIL? If so, all the TILS would fail APOR. What am I doing wrong?