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#2206388 - 02/15/19 07:27 PM Construction Permanent Float Downs and Reg B
Sara Offline
New Poster
Joined: Oct 2018
Posts: 14
Hi!
We do construction to permanent financing in portfolio. Once the construction phase is over we do a "float-down" which is a modification on our construction perm loans to reduce the rate and sell on the secondary market. The documents we provide to the borrower in these modifications include: an updated application, 4506T, borrowers certification and authorization, and a CSDN. Does this trigger anything in Reg B (or FCRA) and would require an Adverse Action Notice if not approved?

Thanks all!

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Fair Lending
#2206407 - 02/15/19 08:29 PM Re: Construction Permanent Float Downs and Reg B Sara
Rocky P Offline
Power Poster
Joined: Jun 2003
Posts: 7,659
Florida
Usually the construction permanent is automatic - the lender is approving both sides simultaneously.
Under what conditions would the permanent be denied?
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#2206413 - 02/15/19 09:04 PM Re: Construction Permanent Float Downs and Reg B Sara
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 83,371
Galveston, TX
Isn't the float down covered in the original loan agreement and what conditions have to be met for them to qualify?
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