We originated a loan - 25 year ARM loan - that was a cash out on a dwelling owned free and clear. The customer was using the funds to construct another dwelling to be rented which we did not take as collateral. This was not a typical construction loan that would have a construction phase with a permanent financing stage. It was permanent financing from the beginning and we did not monitor the construction of the dwelling. It was a complete cash out amortizing loan. Would it still be reportable as a purchase?
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