Do we have to report the end loan of a 2X-Close Construction to Perm loan, if the construction loan does not originate?
I was trained to NOT report the end loan to HMDA since the construction loan did not close. My predecessor stated it is due to the 2X-Close having 1 application and the construction phase is not HMDA reportable. Something along the lines that if the construction phase never closed, there really can't be an end phase (but we do disclose the end loan and use the same app date as the construction loan)...
However, when the end loan does close, my FI reports the end loan to HMDA.
I have a bad feeling about this...have we been reporting (or lack thereof) incorrectly?
Thoughts? Thank you...