will the bank need to verify this after then initial 12 months and then again at the permanent financing stage?
You topic refers to 18-24 months Const/Perm loans. I'm not sure about your reference to the initial 12 months. If the construction phase is greater than 12 months then the construction phase is not exempt from the ATR requirements.
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The opinions expressed are mine and they are not to be taken as legal advice.