Well, I suppose you could. I think it depends on how far along the project might be:
Accordingly, the Bureau is revising comment 37(a)(9)-1.iii to refer to
initial construction and to clarify that this disclosure does not apply to renovations. The Bureau
is further revising § 1026.37(a)(9)(iii) to state that a loan is for “Construction†only if it will be
used to finance the initial construction of a dwelling and is not for one of the purposes described
in § 1026.37(a)(9)(i) or (ii), for the reasons discussed in the section-by-section analysis of
§ 1026.37(a)(9)(ii). Accordingly, credit obtained for the purpose of renovation shall be disclosed
as a refinance or home equity loan, as applicable.
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The opinions expressed here should not be construed to be those of my employer:
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