We are having a debate here at the bank on whether we should early disclose on the following scenarios:

1. 12 months interest only construction loan preapproved through the secondary market.

2. 12 months interest only construction loan. Cannot go secondary market because of a bankruptcy (credit score still 703, makes no sense). We do not want to do a one time close. After the temp financing we will do another loan to pay this one off and put on a payout.

We do not want to do one time closings because they are such a pain. When do we disclose on each of these scenarios.

Both scenarios require you to provide the GFE and ETIL for the construction phase and permanent phase within 3 business days of receiving the application.

See 1024.5 - . . .if the loan is used as, or may be converted to, permanent financing by the same lender . . .

What is the pain in a one time close? Two time close requires two times the work...

Curiously, is #1 secondary market through your bank or another institution? If it's a different FI and you have a takeout...it would be temporary.