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#1986786 - 01/07/15 02:05 PM Construction conundrum
low profile Offline
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low profile
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Pennsylvania
When preparing documentation for a construction loan closing is it advisable to combine the construction and permanent phase on one disclosure form or to provide two disclosures at closing, one for the construction period and one for the permanent phase?
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Lending Compliance
#1986830 - 01/07/15 03:20 PM Re: Construction conundrum low profile
Rocky P Offline
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Florida
What do your procedures say? Check with counsel.

1 form - less paperwork
2 forms - more accurate because less variables
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#1986832 - 01/07/15 03:22 PM Re: Construction conundrum low profile
rlcarey Online
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What disclosure form is being referred too??
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#1986840 - 01/07/15 03:29 PM Re: Construction conundrum rlcarey
Rocky P Offline
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Florida
Randy, I was assuming the TIL
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#1986852 - 01/07/15 03:49 PM Re: Construction conundrum low profile
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Rocky is correct, I was referring to the TIL, from a regulatory perspective, are both options compliant?
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#1986855 - 01/07/15 03:51 PM Re: Construction conundrum low profile
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Both approaches are acceptable. See Appendix D.
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#1986856 - 01/07/15 03:52 PM Re: Construction conundrum low profile
Richard Insley Offline
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Richard Insley
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Toano, VA
Originally Posted By: low profile
are both options compliant?
Yes, but combo disclosures are much more susceptible to errors (the reimbursable kind...been there, done that) than separate disclosures. Divide and conquer!
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#1987026 - 01/07/15 07:29 PM Re: Construction conundrum low profile
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Pennsylvania
Thanks guys.
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