Is this considered temporary financing and not HMDA reportable.
Financing a loan to a developer to both purchase a dwelling, which will be torn down and to construct two condo units which will be sold upon completion.
Most on here will look at the "forward use" of the building and say it is not reportable. The reasoning is that the structure is not goingto be used as a dwelling and the spec homes (condos) are not reportable due to the 2017 HMDA final rule. As you will see in the referenced thread, there have been some conflicting responses from the CFPB, so you will need to pick a method and be consistent.
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Adam Witmer, CRCM
All statements are my opinion, not those of my employer, and should not be taken as legal advice. www.compliancecohort.com
When I read the 2018 HMDA getting It Right Guide listed on page 34 are four examples for temporary financing. The last example states that a loan to an investor to purchase a home, renovate it and sell is "Not" temporary financing because the loan is not designed to be "replaced by" separate permanent financing. Am I misunderstanding this example to be the same as my question.
raitchjay
Power Poster
Joined: Oct 2009
Posts: 9,104
OK
But that's not your scenario.....they're not buying a home to flip it....they're buying a "home" (really, just an abandoned building) to raze it and construct spec homes.