[TheBank]

A consumer loan to purchase a dwelling, make improvements/rehab the dwelling, is usually placed in our construction loan product. That product is a closed end loan. If the borrower plans to obtain permanent financing at maturity, that fist loan to purchase and rehabilitate the dwelling would not be HMDA reportable. However if the borrower does not plan to obtain a permanent financing loan, and pays off the construction loan, that would be HMDA reportable, is that your understanding as well?

[jholzknecht]

I agree with your analysis. A temporary loan is exempt from HMDA reporting requirements. A loan is temporary if it is designed to be replaced by a separate permanent financing extended by any financial institution to the same borrower at a later time.

[Author]

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