Okay most likely a silly question but it is early and HMDA hurts my head recently. Doubting everything these days.

We do one time close construction to perm loans. What would the term be under 1003.4(a)(25)? We have a 6 month construction period with a 360 month amortization period on the permanent loan. I have read the reg and the commentary. With a literal read "The scheduled number of months after which the legal obligation will mature or terminate or would have matured or terminated." For action take date 1003.4(a)(8)(ii)-5 we use account opening date. I would say 366 but then I doubt my self as this is two separate transactions and the fully amortizing period for the obligation is only 360 months.

Any thoughts, points I missed, etc would be appreciated.

I have same question

I see the answer as being 366. It's not two separate transactions....it's one loan.

Quest Soft is converting it to 360 no matter if we put 366.

We add the number of months in the construction phase to the number of months in the perm phase.

I don't see how you have two transactions in a one-time close construction/perm loan. You certainly may disclose it that way under Reg Z but it's still one transaction.

For a fully amortizing covered loan, the number of months after which the legal obligation matures is the number of months in the amortization schedule, ending with the final payment. Some covered loans do not fully amortize during the maturity term, such as covered loans with a balloon payment; such loans should still be reported using the maturity term rather than the amortization term....and so on.

I am taking this to mean you report the maturity term of 360 rather than the amortizing term. But I could be looking at it completely backwards!

We are struggling with the same issue on a one-close construction-perm. What is the final verdict? Add construction only term to 360??

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.