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"Sale Price" On LE/CD for Transaction w/Seller

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Asking this question for both current and future rules: On a construction-permanent loan application that has only one closing and one set of LE/CD disclosures for the transaction, what should the "sale price" be on the LE/CD with a transaction that involves a seller? Should it only be the amount of the purchase price or should the cost to construct be included with the purchase price? I'm leaning towards the purchase price only based on 1026.37(a)(7) but we've been adding in the construction costs for some time now without criticism...

If a seller is involved, it is always the sales price. There was no change to that requirement in the amendments. If there is no seller involved, then you are allowed to consider the projected improvements in the estimated value.

First published on 01/06/2019

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