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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My opinion, take it for what its worth. Opinions expressed are my own and not those of my employer and are not legal advice.