Registered as new construction.
It is a new home, on new foundation.- signs point to Home Purchase w/o RTC

BUT

While they were building, they lived in the accessory unit on the property. Appraiser treating as guest cabin. It is a little cabin suitable for year round occupancy with bedroom, bath, kitchen, living and dining room area. Does this change things?

It appears the structure is the consumer's primary residence at the time of loan closing. IMO rescission applies.

that's were I was leaning.
So refi for HMDA and ROR.
Thanks, Dan.

Sure, as soon as I decide one way they throw me new info.
Buyer has moved into newly constructed home.
Do you agree that it now is Purchase and no ROR?

hat's were I was leaning.
So refi for HMDA and ROR.

If it is converting a construction loan to perm it would be a home purchase for HMDA


Sure, as soon as I decide one way they throw me new info.
Buyer has moved into newly constructed home.
Do you agree that it now is Purchase and no ROR?

If that is what actually took place then I would agree it would be a Residential Mortgage Transaction.