We are having a disagreement on whether or not a Denial for a construction only loan will be put on the LAR. I believe that it is reported, but I am getting push back that it is not to be put on the LAR because it would be temporary financing. Please help.

First you have to determine if it is or isn't temporary. How were they to repay you?

We would be replacing with permanent financing upon completion of the construction.

If it’s a construction only and not replaced by permanent financing with you or another institution, then it is a short term loan and not temporary. Short term loans are reported.

To be exempt as temporary financing, loans must have 2 phases beginning in 2018.

So you knew going in that you would be doing the perm? Then you had an application for both a CL and a perm loan. The perm loan would be reportable.

Thank you both. I appreciate it.