[Jean]

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

Topic

[JGo9]

Jean,

You are correct in that full RESPA does apply.

[Author]

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