Skip to content
BOL Conferences
Thread Options
#1918433 - 04/29/14 03:51 PM Construction to Permanent
Lu Offline
Platinum Poster
Joined: Apr 2002
Posts: 597
this loan was made in Jan 2013 construction. 2014 they have modified (not refi)the same loan to term out the financing for 5 yrs.
What date do we use for the loan date now? It was not on HMDA in 2013 because it was construction.
If at the original time we knoew that it is going to be const to perm, do we report it as purchase then?
_________________________
"If you only laugh and enjoy life when your problems are all solved, you'll never enjoy life."

Return to Top
HMDA

   
HMDA Academy
#1918568 - 04/29/14 07:08 PM Re: Construction to Permanent Lu
Rocky P Offline
Power Poster
Joined: Jun 2003
Posts: 7,650
Florida
It started out as a construction loan.
What date did the customer request that it be termed out to 5 years? That would be the application date IMO.
_________________________
Integrity. With it, nothing else matters. Without it, nothing else matters.

Return to Top
#1918587 - 04/29/14 07:38 PM Re: Construction to Permanent Lu
raitchjay Offline
Power Poster
Joined: Oct 2009
Posts: 9,086
OK
Unless something has changed, aren't modifications not reportable at all?
_________________________
I'm fixin' to fix that.

Return to Top
#1918606 - 04/29/14 08:05 PM Re: Construction to Permanent Lu
Rocky P Offline
Power Poster
Joined: Jun 2003
Posts: 7,650
Florida
RJ, I had thought of that (mod = no HMDA report), but also thought that the bank making a permanent loan would be more right to report than ignore. Based on mods not being reported, I agree that is a more defensible position.

Return to Top
#1918610 - 04/29/14 08:11 PM Re: Construction to Permanent Lu
raitchjay Offline
Power Poster
Joined: Oct 2009
Posts: 9,086
OK
I'm not very familiar with banks making construction loans and then modifying them (as opposed to actually refinancing the temporary loan into a permanent loan); i'm not sure how kosher that is (it might be very kosher, just not sure and not familiar).
_________________________
I'm fixin' to fix that.

Return to Top
#1918625 - 04/29/14 08:33 PM Re: Construction to Permanent Lu
Lu Offline
Platinum Poster
Joined: Apr 2002
Posts: 597
The original approval states that it will be construction for 1 year and then termed out to 10 yrs. So should it be HMDA at the origination.
_________________________
"If you only laugh and enjoy life when your problems are all solved, you'll never enjoy life."

Return to Top
#1918637 - 04/29/14 08:50 PM Re: Construction to Permanent Lu
raitchjay Offline
Power Poster
Joined: Oct 2009
Posts: 9,086
OK
Sorry if i misunderstood. If this loan closed as a true, 2-phase construction-permanent loan, then yes, it would be reportable. We don't do these types in my shop, but i believe you have the option of reporting them at origination or at the date they switch over to permanent financing.
_________________________
I'm fixin' to fix that.

Return to Top
#1918675 - 04/29/14 11:46 PM Re: Construction to Permanent Lu
Kathleen O. Blanchard Offline

10K Club
Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,293
Yes, if you knew it was to be construction perm you have a choice.

Re mods, regulators have stated that for mods to perm from construction it should be reported as a purchase as the mod if providing the long term financing. The HMDA rule for not reporting mods speaks to refinances. Now this goes down a twisty turny path, but it has been a few years now since the statement re mod to perm was made (pre-CFPB). There are threads here on the topic.
_________________________
Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

Return to Top

Moderator:  SMQ, CRCM