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BankersOnline.com Forums Dodd-Frank Final Rules Discussions Ability to Repay/Qualified Mortgage Rule construction to perm application date
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#1926864 - 05/27/14 09:25 PM construction to perm application date
ADN Offline
100 Club
Joined: Mar 2007
Posts: 222
We have a borrower that applied for a construction loan and we provided earlies based on two phase financing back in 2013. The construction phase is about over and we are wanting to move to the permanent phase. Would the new requirements (appraisal, ATR, etc) apply since technically they applied for their loan back in 2013?

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Ability to Repay/Qualified Mortgage Rule
#1926909 - 05/28/14 12:39 PM Re: construction to perm application date ADN
rlcarey Offline
10K Club
rlcarey
Joined: Jul 2001
Posts: 83,363
Galveston, TX
You issued the original GFE, early TIL, etc. last year - correct. Then I would say your application date is prior to January 10th.
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#1926960 - 05/28/14 02:13 PM Re: construction to perm application date rlcarey
ADN Offline
100 Club
Joined: Mar 2007
Posts: 222
Thanks for the response!

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