The HMDA GIR manual seems to imply that the permanent piece of construction to permanent loans (at the point the permanent loan is settled, after construction is complete) should be reported as a home purchase. I've read threads debating this and still don't know which way to go. The HMDA-GIR manual seems clear that it should be a "purchase", even though this isn't logical to me. Does anyone know for sure?

Thank you.

Yes, a construction/perm loan should be coded as a purchase.

I concur with Lee. Construction loans converting to permanent loans are reported as purchases, even if you are paying off another financial institution's construction loan.

I always think of it this way: I construct the house, then I buy it. That makes sense for HMDA, RofR and P-TIL disclosures.