[kmeade]

Do we need to collect monitoring information if a borrower is refinancing a construction loan, with another construction loan to receive additional cash out to complete construction? I am debating, because this loan meets the definition of refinance and the definition of temporary financing. The permanent loan will be a separate loan and it will be their primary residence when construction is complete. Per 1002.13(a)(3) do we need to collect monitoring information for this loan?

1002.13(a)(3). Temporary financing. An application for temporary financing to construct a dwelling is not subject to § 1002.13. But an application for both a temporary loan to finance construction of a dwelling and a permanent mortgage loan to take effect upon the completion of construction is subject to § 1002.13

[rcooper]

Sounds like you have only a construction loan, not a construction-perm. Based on the section of the commentary you cited above, I don’t think you would collect.

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