I'm going to try to lay this all out to make the question as clear as possible. I'm looking at reporting Total Loan Costs for a one-time close construction to perm loan. The total term of the loan is 372 months, with the first 12 payments being interest only, and the final 360 being regular amortizing payments.

The loan software wants me to report NA for these types of loans for Total Loan Costs. I understand that Total Loan Costs is reported as NA if the loan is not subject to 1026.43(c). Does the fact that the first 12 months are exempt from 1026.43(c) exclude us from reporting the total loan costs? I've always thought that since the perm portion is subject to 1026.43(c), we would report total loan costs.

Thoughts?

No clue - you need to contact your loan software provider.

Obviously the loan software provider thinks it should be NA. I think we should report total loan costs. I'm just asking for others opinions on reporting the number or reporting NA. Thanks Randy.

I think what Randy is implying is you need to find out why the software provider is using NA for that category.

A const/perm loan is a reportable home purchase loan and as for as I know HMDA does not differentiate between the costs for the construction portion and the costs for the permanent portion.

Thanks to both of you. I will do that, I just wanted to see if I was completely off base with my position prior to doing so.

Have a great day!

We report total loan costs for our construction/perm loans.