Customer is purchasing a building to construct 4 condominiums. The loan is a non-revolving line of credit for 18 months. The customers plans to pay off the line of credit with the sale of the condominiums or if not sold, rent them out. Per loan officer's assistant there is no plan to refinance. To me, this seems like a purchase, any other thoughts? Thank you in advance.

I agree. If there's plan to refinance, it's not 2 phases and not temporary. It's a short term purchase and reported as a purchase. Much like a "splash and dash" or "flipping" loan.

How about a commercial loan that is classified as a commercial construction loan to finance the acquisition and renovation of a single family house for investment purposes?

In the regulation, construction only loans are not reported, but this is not a ground up construction. Would you report?

Thank you!

Yes. A loan has to meet the Reg. C definition of "construction only" to get that exemption. If the plan is to buy and flip a house, it's reportable.

Thank you! Happy Memorial Weekend!!

Yw....you too.