Answer:
You will find your answers by reviewing the definition of a Residential Mortgage Transaction in Reg Z's 226.2(a)(24) and its related Commentary. Construction/permanent loans are indeed Residential Mortgage Transactions (RMT), if they meet the definition cited above, and are exempt from the ROR. The permanent loan that replaces a construction only loan is also a RMT and exempt from the ROR.
Click here for a discussion on "new money." After reading this thread you should also review 226.23 and its Commentary and/or 226.15 for open-end credit.
First published on BankersOnline.com 7/24/06