Answer:
HMDA states that construction to permanent is always reported as a purchase. It doesn't matter that a different lender did the construction phase.
First published on BankersOnline.com 7/06/09
HMDA Reporting - Permanent Financing
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Question:
We have a loan that we took over from another bank. The other bank did the construction loan for the customers and we are doing the permanent financing for them. Since the construction part of the loan was with another lender, would we still report this as a construction/perm which would be a purchase loan under HMDA, or would we need to report it as a refinancing loan under HMDA?
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