We are doing a construction-only loan to an existing borrower and a co-borrower. The lot is currently in the borrower's name only. The balance of the lot loan will be rolled into this construction loan. An act of donation will be done at loan closing to put the property in both borrower & co-borrower's name. Both will be on title and the promissory note. Do we report this as a purchase for TRID since the names on title are changing?

You seem to indicate there is an existing lot loan. Is this the case, such that the new loan is satisfying and replacing the existing lot loan?

It's a refinance.

yes, an existing lot loan that will be satisfied and replaced with the new construction-only loan. This would typically be reported as a refinance for TRID. My question is because the co-borrower will be added to title via an Act of Donation, will that make this a purchase for TRID?

This

If they are donating the property to the other borrower, how does this turn the loan into a purchase transaction. The donation has nothing to do with the loan.

My train of thought never got me to the station....it didn't cross my mind. Thanks. It's obvious now...refinance.

Yep. That's where I was going with my question, but just wanted to make sure. As Randy stated, this doesn't have anything to do with the purpose of the loan in this situation.