Similar question, but not quite the same. Bank is doing a temporary finance loan to construct a new property. If not doing the perm, then a temp. finance loan would not be reportable; however, the Bank is also taking additional collateral in the form of the customer's current primary dwelling. Is this a purchase because of the current primary dwelling securing the loan, or is it excludable because what is being "purchased" would still just be the lot and materials under an excluded from reporting (temp. financing) loan? Thank you for your time and assistance.
Super old, but I found this thread that may still apply - https://www.bankersonline.com/forum/ubbthreads.php/topics/482149/7
The scenario I presented sounds like what is called a "Bridge" loan in this thread. So, it would seem that if the loan will be paid off through permanent financing, then the loan would not be HMDA reportable; however, if it is not designed to be paid off by permanent financing, then it would be HMDA reportable. Sound about right?