We closed a construction perm (single closing). When the construction phase ended, we did a modification to the permanent phase.

This is a secondary market loan and the correspondent asked us for the GFE when the loan was modified.

HELP - was a GFE necessary?

Not in my opinion...modifications are not subject to disclosures. If the old note was replaced with a new note, however, it would be a refinance, not a mod, and would have required disclosure.

I'm curious, "We closed a construction perm (single closing).", why did you do a modification when the construction phase was complete?

I think this is an old method that has seen its time come and go. What I have seen, is tHe original note is a construction note and then it is completely modified into a closed-end permanaent loan. IMHO, a modification of this magnitude most likely replaces the original obligation and it is a refinance and triggers all new disclosures. They need to huddle with their attorney on this issue and figure out how to do this going forward with a true construction/perm note.

Has anyone found a vendor that has an accurate construction/perm note?

Maybe they are asking for the perm disclosures that should have been done at application. We do the construction loan and then either a secondary market perm or a Modification into amortized payments. Either way, we provide the construction as well as the perm disclosures at application.