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Construction Draw Down Line of Credit- HMDA?

Answered by: 
Randy Carey
Dan Persfull

Question: 
We have a commercial customer doing a construction draw down line of credit. The construction and collateral will be a single family residence. t's a three year term.The first two years the line is a draw down line of credit, ​with ​interest​only ​payments; the last year it will be P&I with a balloon ​payment​​. Is this line/loan ​HMDA-reportable?
Answer: 

by Randy Carey:

It is not a line of credit, it is a closed-end loan. Sounds like a short term reportable loan to me.

Answer: 

by Dan Persful:

I agree. The way this loan is schedule I would have to opine it's a construction-permanent loan and those are reportable.

First published on 01/13/2019

Filed under: 
Lending
Filed under lending as: 
HMDA

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