Hi All,

Are non-orignated Construction/Permanent loans HMDA Reportable?

Yes. If the loan would have been reportable had it originated, it is also reportable if it doesn't.

Agree with hmdagal. If the application is subject to HMDA reporting you would need to report the non-originated application.

Ok we would have reported the loan when it went into the permanent phase of the loan not at the time it is in the construction phase. So since this loan did not get to the permanent phase of the loan process is it still reportable?

Ok we would have reported the loan when it went into the permanent phase of the loan not at the time it is in the construction phase. So since this loan did not get to the permanent phase of the loan process is it still reportable?

You approved the permanent phase, it did not originate, why would you contend it's not reportable?

Also if this was to be a single close const/perm loan that closed in 2014 but the perm phase did not kick in until 2015 you would be required to report it on the 2014 LAR. See page D-9 of the GIR.

Thanks Dan, That is a good point. Never thought about it going on the 2014 LAR.