During a loan file review, I found a construction-only loan that when the dwelling is completed in one year the perm financing will be with another bank. In the loan application, the mortgage originator did not complete the demographic information on the borrowers. I know that land-only loans are not HMDA reportable - but I was told by the Loan Operation Manager that this was construction only and we did not have to report this loan because we won't have the loan when the dwelling is completed. In HMDA Getting it Right - it indicated: Comment 3(c)(3)-1. A construction-only loan or line of credit is considered temporary financing and excluded under Regulation C if the loan or line of credit is extended to a person exclusively to construct a dwelling for sale. Comment 3(c)(3)-2.
I just want to be sure that this loan is not reportable. The borrowers are the ones who will be residing in the home once completed. This is n't a developer or business selling the home. The structure is already started.