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Two Sets of Disclosure for Const. and Future Perm?

Answered by: 
Randy Carey

Question: 
We (local bank) are doing a construction loan for a customer who already owns the land.Normally RESPA would not apply, however, we have also approved to handle the permanent financing in-house upon completion. Do we provide RESPA early disclosures for the construction loan only at this time, and new earlies when we refinance to the perm loan; Or, do we provide two sets of earlies now, one for the construction loan, and one for the future perm loan?
Answer: 

A GFE and early TIL have to be delivered within three days of application for the permanent loan. It sounds like they will be applying simultaneously, so they would get a set of disclosures for both the construction loan and the permanent loan at that time.

First published on BankersOnline.com 7/16/12

First published on 07/16/2012

Filed under: 
Compliance
Filed under compliance as: 
Disclosures
IT
RESPA

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