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#2181961 - 06/15/18 05:09 PM "Comparable Loan" APOR for Construction-Permanent
GTS333 Offline
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Joined: Jun 2010
Posts: 257
I didn't see an answer to this specific question in the existing HMDA threads, so I'll pose it now in hopes someone has a good citation I've missed to answer this question.

For a HMDA reportable construction-permanent loan (one that automatically converts from the construction to permanent phase), is the "comparable transaction" we use for rate spread purposes (1003.4(a)(25)) a transaction that includes the both the construction and permanent phase, or is it just the permanent phase? Obviously one is longer period than the other, but I can't seem to find anything that says which to use specifically for rate spread.

Thank you.
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#2182019 - 06/15/18 10:06 PM Re: "Comparable Loan" APOR for Construction-Permanent GTS333
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 83,227
Galveston, TX
There is no carve out for a one-time close - the loan term is the loan term.
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#2182053 - 06/18/18 02:22 PM Re: "Comparable Loan" APOR for Construction-Permanent GTS333
GTS333 Offline
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Joined: Jun 2010
Posts: 257
Thanks rlcarey. That' s where I came to on the issue as well, though I was curious if I had just missed something.
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My opinion, take it for what its worth. Opinions expressed are my own and not those of my employer and are not legal advice.

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