[Gholloway]

We have a loan with the purpose to obtain additional funds to complete the construction of a dwelling. The loan is to a builder, and the loan is not temporary financing. Would you consider this a HMDA reportable loan? Would it be a home improvement or purchase?

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[kowsley]

I think I need additional information to better answer this question. Since you stated that the loan is not temporary financing, I assume that this is a construction to permanent loan? Are you doing a completely separate loan for the costs overrun or are you refinancing the original loan and adding the additional funds?

[Gholloway]

yes it is construction to permanent. And it is a separate loan that was made from the original loan for construction.

[kowsley]

It is HMDA reportable as it is a dwelling and is considered construction to permanent. It would be exempt as temporary financing if it was construction only. See below for guidance from the regulation:

1003.2 Definitions: 5. Construction and permanent financing. A home purchase loan includes both a combined construction/permanent loan and the permanent financing that replaces a construction-only loan. It does not include a construction-only loan, which is considered “temporary financing” under Regulation C and is not reported.

[Author]

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