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#2257410 - 07/29/21 08:50 PM ECOA and construction loans
Anonymous
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Hope this makes sense, I understand that construction loans are exempt from collecting ECOA monitoring information.

Does the fact that we payoff an existing mortgage on the land with the initial draw on the construction loan change the exemption?

Would a construction loan to renovate an existing dwelling be exempt if the loan also purchases the dwelling or refinances the existing mortgage. The primary purpose of our loan is the construct/renovate but it could also be a purchase or refinance.

Thanks!

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#2257427 - 07/30/21 10:21 AM Re: ECOA and construction loans Anonymous
InFairness, CRCM Offline
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Can you give a little more detail on construct/renovate? Is the existing dwelling being enhanced, or is it being replaced with a new dwelling?
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#2257432 - 07/30/21 01:53 PM Re: ECOA and construction loans Anonymous
raitchjay Online
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My read on the original post is that a land only loan is getting refinanced with additional funds to construct a dwelling. I believe this would still be exempt from GMI/DI collection.
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#2257459 - 07/30/21 05:51 PM Re: ECOA and construction loans Anonymous
Dan Persfull Offline
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3. Temporary financing. An application for temporary financing to construct a dwelling is not subject to § 1002.13. But an application for both a temporary loan to finance construction of a dwelling and a permanent mortgage loan to take effect upon the completion of construction is subject to § 1002.13.

A renovation loan is not a loan to construct the dwelling.
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#2257479 - 07/30/21 08:15 PM Re: ECOA and construction loans Anonymous
raitchjay Online
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I totally missed that part......i thought this was construction, but upon re-reading...i see that it is not. My apologies, and i agree with Dan.
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#2257496 - 08/02/21 02:43 PM Re: ECOA and construction loans Anonymous
Dan Persfull Offline
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Raitchjay - your answer would be correct for the first part of the question concerning paying off a land loan with the construction proceeds. My answer was to the second part of the question concerning renovation loans.
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#2257509 - 08/02/21 05:01 PM Re: ECOA and construction loans Anonymous
raitchjay Online
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Dan.....the post, upon re-reading, confused me. The first part is basically all i read and comprehended evidently. I can't tell now whether the post was asking about 1 scenario or 2.
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#2257530 - 08/02/21 07:15 PM Re: ECOA and construction loans Anonymous
Dan Persfull Offline
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I took this as question 1:

Does the fact that we payoff an existing mortgage on the land with the initial draw on the construction loan change the exemption?

And this as question 2:

Would a construction loan to renovate an existing dwelling be exempt if the loan also purchases the dwelling or refinances the existing mortgage. The primary purpose of our loan is the construct/renovate but it could also be a purchase or refinance.
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#2257536 - 08/02/21 07:36 PM Re: ECOA and construction loans Anonymous
raitchjay Online
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Dan....that makes sense. I was trying to read it as one scenario, and it seemed contradictory. As 2 separate questions, it makes a lot more sense.
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