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#2166398 - 03/01/18 08:02 PM Commercial Construction
Tracey, CRCM Offline
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Gorham, ME
Borrower is a LLC that gets loans to build single family homes. Loan is then paid off when home is sold (these are not spec homes, they have purchasers). Security is the house being built (at time loan closes, its just a lot).

HMDA reportable in 2018?
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#2166403 - 03/01/18 08:18 PM Re: Commercial Construction Tracey, CRCM
RR Joker Offline
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The Swamp
No
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#2166404 - 03/01/18 08:19 PM Re: Commercial Construction Tracey, CRCM
Tracey, CRCM Offline
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Gorham, ME
Whew. That is what I thought but I was second guessing myself.

Thank you RR!
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#2176936 - 05/07/18 03:22 PM Re: Commercial Construction Tracey, CRCM
Catm1991 Offline
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MO
So, if the loan is a purchase of an empty lot, 12 months, and they state it is too build a residential dwelling, and will pay off when house sells.....this is not reportable???

I would have thought that it would be.

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#2176938 - 05/07/18 03:24 PM Re: Commercial Construction Tracey, CRCM
RR Joker Offline
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Spec construction is not reportable, correct.
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#2176942 - 05/07/18 03:32 PM Re: Commercial Construction Tracey, CRCM
Catm1991 Offline
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MO
So, all construction loans are non - reportable???

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#2176944 - 05/07/18 03:38 PM Re: Commercial Construction Catm1991
NSF, CRCM Offline
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NSF, CRCM
Joined: Apr 2013
Posts: 410
VA
Originally Posted By Catm1991
So, all construction loans are non - reportable???


No that is not accurate. Refer to the commentary of REG C:

Paragraph 3(c)(3)

1. Temporary financing. Section 1003.3(c)(3) provides that closed-end mortgage loans or open-end lines of credit obtained for temporary financing are excluded transactions. A loan or line of credit is considered temporary financing and excluded under § 1003.3(c)(3) if the loan or line of credit is designed to be replaced by separate permanent financing extended by any financial institution to the same borrower at a later time.

2. Loan or line of credit to construct a dwelling for sale. A construction-only loan or line of credit is considered temporary financing and excluded under § 1003.3(c)(3) if the loan or line of credit is extended to a person exclusively to construct a dwelling for sale. See comment 3(c)(3)-1.ii through .iv for examples of the reporting requirement for construction loans that are not extended to a person exclusively to construct a dwelling for sale.
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#2176974 - 05/07/18 04:33 PM Re: Commercial Construction Tracey, CRCM
Catm1991 Offline
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MO
And I was just looking over some of the older post, and want too be sure I am correct with the new, "pecking order for HMDA"..

Am I correct in that it is now?
Purchase
Refinance
Refinance Cash Out
Home Improvements

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#2176989 - 05/07/18 04:54 PM Re: Commercial Construction Tracey, CRCM
raitchjay Offline
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OK
Refi and cash out refi should really be 2. and 2a. since even if you need to report a cash out, it can't be both a cash out and a non-cash out. And don't forget that you now have an "other" at the bottom (for home equity loans).
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#2177056 - 05/07/18 08:42 PM Re: Commercial Construction Tracey, CRCM
Catm1991 Offline
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Joined: Jul 2014
Posts: 194
MO
We do not code them differently, all of our's in our JHA/OnBoard systems are coded refinances...so I guess most of ours will just be refinances (none will be refinance cash out). This is what I have been doing, but I just wanted too double check.

Thanks.

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#2177058 - 05/07/18 08:44 PM Re: Commercial Construction Tracey, CRCM
raitchjay Offline
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If you don't have to report anything as a cash out refi, then your hierarchy would basically be:

Purchase
Refinance
Home Improvement
Other
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