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#2211597 - 04/18/19 11:51 PM IS ROR Required on a Permanent Takeout of A Constr
CMSIngenue Offline
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Is the Right of Rescission required on a permanent take out of a construction loan? Can someone provide the statutory cite on where I can find the answer in Reg Z?

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TRID - TILA/RESPA Integrated Disclosures Rule
#2211599 - 04/19/19 12:59 AM Re: IS ROR Required on a Permanent Takeout of A Constr CMSIngenue
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 79,675
Galveston, TX
Official Interpretation

2(a)(24) Residential Mortgage Transaction

Comment 4
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#2214531 - 05/29/19 06:15 PM Re: IS ROR Required on a Permanent Takeout of A Constr CMSIngenue
Love those Regs Offline
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Just wanting to double check - we did the construction loan and was not certain who would provide permanent financing. We ended up doing the permanent - we did a change in terms rather than a new note - does that make any difference? I'm still thinking this is a residential mort. transaction and ROR does not apply. No new funds. Simply terming out the construction loan.
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#2214536 - 05/29/19 06:38 PM Re: IS ROR Required on a Permanent Takeout of A Constr CMSIngenue
rlcarey Online
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rlcarey
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Galveston, TX
Construction financing. If a transaction meets the definition of a residential mortgage transaction and the creditor chooses to disclose it as several transactions under ยง1026.17(c)(6), each one is considered to be a residential mortgage transaction, even if different creditors are involved.
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