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#1821889 - 06/07/13 11:54 PM Construction/perm loan -GFE one approval two notes
Chocaholic Offline
Gold Star
Joined: Aug 2005
Posts: 443
Northwest
We are new to this process. In the past we have done construction loans only, requiring borrowers to go elsewhere for long term financing.Now managment has decided we should do it all. In reviewing Reg. Z Appendix D it suggests that we can choose to either disclose construction & long term separately using Part 1 or we can disclose under part 2 all terms together. My question has to do with the GFE and the estimated construction interest and using part 2. I suppose we are lucky since construction interest rate and long term rate is the same.
Where do we disclose the estimated interest on the GFE and shouldn't it be included in the finance charge.

Our disclosure does not look right. The statement that Interest on the amount outstanding will be paid monthly appears on the TIL but it does not appear it is factored into the APR.. we are using Laserpro... anybody have a suggestion as to what we might be doing incorrectly.

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Lending Compliance
#1823064 - 06/12/13 09:13 PM Re: Construction/perm loan -GFE one approval two notes Chocaholic
travelchic Offline
New Poster
Joined: Jun 2011
Posts: 19
Harland has an article titled "Laser Pro Consumer Construction-Permanent: Tips, Tricks, and Considerations". Great article, walks you through the software and the Reg. This should answer your question. If you will PM your email I will send you a PDF of the article.

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#1823068 - 06/12/13 09:18 PM Re: Construction/perm loan -GFE one approval two notes Chocaholic
travelchic Offline
New Poster
Joined: Jun 2011
Posts: 19
Article states that Part II.A.2 is extremely rare and is not supported.

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