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#2259118 - 09/01/21 08:08 PM HMDA Purpose
Leigh0508 Offline
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Joined: Aug 2021
Posts: 3
Per HMDA, a construction to perm loan falls under "purchase". In the event a customer own the lot free and clear, and wants to do a C2P one time close loan, does this still get reported as a purchase or would this fall under "other"?

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#2259123 - 09/01/21 08:44 PM Re: HMDA Purpose Leigh0508
hmdagal Offline
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hmdagal
Joined: Dec 2002
Posts: 3,841
Assuming they are building a dwelling on the lot, it would be a purchase:

3. Construction and permanent financing. A home purchase loan includes both a combined construction/permanent loan or line of credit, and the separate permanent financing that replaces a construction-only loan or line of credit for the same borrower at a later time. A home purchase loan does not include a construction-only loan or line of credit that is designed to be replaced by separate permanent financing extended by any financial institution to the same borrower at a later time or that is extended to a person exclusively to construct a dwelling for sale, which are excluded from Regulation C as temporary financing under § 1003.3(c)(3). Comments 3(c)(3)-1 and -2 provide additional details about transactions that are excluded as temporary financing.

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#2259243 - 09/03/21 02:58 PM Re: HMDA Purpose hmdagal
Leigh0508 Offline
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Joined: Aug 2021
Posts: 3
Thank you!

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