For TRID, If a construction-permanent loan is disclosed as a single transaction (combined LE and combined CD), the loan term is the combined term of both phases. This was made explicitly clear in TRID 2.0 with the addition of comment app. D-7.i.A. I know that you can't translate requirements of one regulation to another, but given that, and given the fact that the construction-permanent loan truly is one loan, I can't see any way that the combined term would not be the correct reported number for HMDA.
Jim Bedsole, CRCM, CBA, CFSA, CAFP
My posts - my opinions