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Permanent Construction Loan

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  • March 15, 2012 at 6:02 pm EDT #2502
    Jean
    Member

    Bank made a construction only loan for 12 months. The transaction was exempt from RESPA due to no transfer of title and we did not contemplate permanent financing. However, now the borrower cannot obtain permanent financing and the bank agreed to finance the mini-perm.
    My thoughts are…full RESPA/TIL disclosures are required and HMDA reportable as a purchase not a refi.

    Is that correct?

    Thanks for you thoughts

    March 20, 2012 at 2:06 pm EDT #2953
    JGo9
    Participant

    Jean,

    You are correct in that full RESPA does apply.

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