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Consumer Construction Loan HMDA Reportable?

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We are doing a consumer construction loan to complete the primary residence. We have a loan amount of $333,000 of which $156,000.00 is going to pay off the first and second mortgage on their current residence, with $177,000.00 going toward completing the construction on their new home. Is this HMDA reportable because we are satisfying a mortgage, even though this is a construction loan? What disclosures are required since we are taking a first mortgage on their primary residence and a first mortgage on the construction home? The term is twelve months interest only, and we are not doing the permanent financing.

This is defined by several regulations as a bridge loan; therefore, RESPA and HMDA do not apply. Reg. Z will be triggered, requiring a final TIL. As you are taking a lien on their principal residence, rescission will also apply.

First published on 7/19/10

First published on 07/19/2010

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