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Early TIL with GFE?

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Question: 
We have a bare land purchase loan that is subject to RESPA, since the customers plan to build within three to six months. Because we now have to issue a GFE at application, don't we also have to issue an Early Truth In Lending now as well?
Answer: 

If none of your loan proceeds are for the construction of the residence, your loan is not subject to RESPA.

First published on BankersOnline.com 6/28/10

First published on 06/28/2010

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