If we provide the Home Loan Toolkit booklet at application for a construction loan, do we have to provide it again if the customer comes to us for their permanent financing once the house is completed or because we issue a new note this is basically a refinance which is exempt from the requirement?

https://www.bankersonline.com/forum/ubbthreads.php/topics/2034194/home-loan-tool-kit

It's required on all new applications. Do you consider the permanent financing to be a new application?

It's required on all new applications.

It is??

(iii) The creditor or mortgage broker need not provide the booklet to the consumer for a transaction, the purpose of which is not the purchase of a one-to-four family residential property, including, but not limited to, the following:

(A) Refinancing transactions;

(B) Closed-end loans secured by a subordinate lien; and

(C) Reverse mortgages.