We are considering a fixed rate construction permanent financing product(same rate for construction & permanent phases). We are planning on creating 1 TIL disclosure, we will not be collecting interest reserves as monthly payments will be billed based on amount advanced during construction phase.

My question then on the first page of GFE -summary of your loan.. what should be used as the inital monthly amount owed for principal & interest.... I am thinking this should be the amortizing payment - is this correct?

My second question is, we will not service the loan if it is a HPML (we have contracted with a vendor to do this)... should we still complete the escrow information if it is a HPML on page 1 of GFE...

1. The payment will the first scheduled interest payment. Page 25 of the 4/2/10 RESPA FAQs.

2. Regardless if you service the loan you are originating it therefore you must meet all the HPML requirements which includes establishing an escrow account.

Thanks Dan,
Then continuing on in the "Summary of Your Loan boxes" Should the answer to "Even if you make payments on time, can your monthly amount owed for principal, interest & any mortgage insurance rise?

My thought is this should be "yes" and then put the end of construction phase ( 9 mo. out or 12 mo out) and the new P & I amortizing payment.

Is this logic sound?

I would agree.