1. I know a construction to perm loan is HMDA reportable. If the loan closed in 2006, but wont convert to perm until 2007, is it reportable with 2006 HMDA date or 2007? I think its 2007, but I would like some confirmation.

2. Majority of the loan was to purchase the land, while a couple hundred thousand was used to build the house. I under the belief this is a home purchase loan. Would this be an accurate assumption?

All help is appreciated.

1. We don't do const to perm loans here so I'll leave that one for someone with more experience. imo, it would be reported when it closed = 2006.

2. Percent of monies used for land vs residence doesn't matter. This is a purchase loan for HMDA.

From page D-12 of the GIR:

"For a construction/permanent loan, the institution reports either the settlement or closing date, or the date the loan converts to the permanent financing. Although an institution need not choose the same approach for its entire HMDA submission, it should be generally consistent (such as by routinely using one approach within a particular division of the institution or for a category of loans). Notwithstanding this flexibility regarding the use of the closing date in connection with reporting the date action was taken, the year in which an origination goes to closing is the year in which the institution must report the origination." [emphasis mine]

I would report the loan in the 2006 HMDA.

1. For Const/perm loans HMDA gives you the option to report when the construction phase begins or when it converts to permanent financing. Most will report when it goes to permanent financing. If you choose that option and the conversion takes place in 2007 then you would report it on the 2007 LAR.

2. TR is correct, this is a home purchase loan unless it meets one of the exemptions.

Thanks for all the input. Its good to know I was on the right track, but I felt I needed some confirmation.