Is anyone out there doing a one time close product where their company is the interim lender, but not the permanent lender. We are the interim construction lender in this process. My dilemma is that from what I understand, two HUD1s (one should be a HUD1a) should be provided at this one closing, one for the interim lender and one for the permanent. The law firm preparing the docs say that one HUD is appropriate. My opinion is that we can only disclose our finance charges in the TIL for the interim, and my understanding is that we should only have the fees for our interim on the HUD. Does anyone else do this type of loan, and how are you disclosing at closing?