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#2209999 - 04/01/19 04:50 PM 2X Close CtoP and 1 App/App Date
Cheli Offline
Platinum Poster
Joined: May 2013
Posts: 919
Good morning/afternoon-
Would a guru be willing to point me to the area in TILA that discusses how a 2X Close Construction to Perm could/would/possibly should have 1 application/application date? I know the rule does not come right out and say it, but it's written in a way where the FI either has a take-out or commitment letter from another institution if doing the Construction Only, OR the FI assumes it will be responsible for the permanent financing as well, and creates the end loan, using the application date of the construction loan...
Can anyone help?
Thank you.

Thank you-

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Lending Compliance
#2210017 - 04/01/19 06:54 PM Re: 2X Close CtoP and 1 App/App Date Cheli
rlcarey Offline
10K Club
Joined: Jul 2001
Posts: 76,990
Galveston, TX
Official Interpretation

19(e)(1)(iii) Timing.

See Comment 5. It all depends on when you get the specific application for each phase. If you never get an application for the permanent loan, you have no responsibility to issue an LE on the permanent loan.
The opinions expressed here should not be construed to be those of my employer:

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