We have a builder that has a $1mm LOC to build spec homes. Normally these houses are sold. However, we now have one that $100k was termed out but the original LOC is still in place. Would this be HMDA reportable as a purchase?

Is this a RLOC or guidance LOC?

RLOC - not reportable IMO. The new loan neither satisfied an existing dwelling secured obligation nor did it convert a construction loan to a permanent loan.

Guidance LOC - if the LOC is evidenced by a "master note" then again I would opine not reportable for the same reasons mentioned above. If however each loan is evidenced by an individual note then I would opine the note executed for the construction phase would be a construction loan being converted to a permanent loan and therefore a home purchase for HMDA reporting.

The above opinions are based on the assumption the term loan was made to the builder.

Dan - I should have been more clear in my original post. It is a RLOC and the term loan is to the builder.

Thanks for the response!