Does ECOA Apply to Interim Construction?

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Question:

We have made a loan to a builder to construct a spec home. Does ECOA apply? The same builder also has a contract build; does ECOA apply to that? We structured both of these as interim construction because both will be refinanced once the homes are complete. Neither will be our borrowers as these are investment properties.

Answer:

The ECOA applies to all loans, so I am not sure what your question might be? If you are talking about the appraisal requirements, it applies to consumer, commercial, temporary loans, etc. exactly