Structure and you can connection money is illustrative, not private, examples of temporary financing
Which accurate point try one of many some thing I pointed out in my own HMDA feedback letter, and you may hopefully might approach it on the finally laws when you look at the a few months.
TMatt is useful there is no particular recommendations during the HMDA for two phase resource on various other finance companies getting a hello loan, but:1) there clearly was clear guidelines to own structure / permanent funds (declaration due to the fact a buy) & 2) if Boaz loans they was basically each other at your lender, you’d declaration the brand new long lasting stage since a hi financing.
So you can opposed to the brand new logic offered in 2 scenarios (and perhaps earn the brand new disagreement) or you can call-it property upgrade financing and make use of this type of dos causes I’ve listed to support the decision.
1) I really don’t understand the relationship anywhere between design/perm and you can temp Hi/refi of temp Hello, nor carry out I’ve found people support for it on GIR. Haven’t got for you personally to go to the Reg by itself.
2)No, We would not in the event the there’s zero brand new money in the next mortgage.And I am not relying on reason. I’m relying on p.29/GIR definition of re-finance.
1) I really don’t see the correlation ranging from framework/perm and you can temp Hi/refi out-of temp Hey, neither perform I find people help for this on GIR. Have not had time for you to check out the Reg alone.
Truffle and you can TMatt: I could support your position. I really don’t thought you will end up cited. I do believe there can be reasoning each other ways. That is section of what i love and you can dislike throughout the HMDA. I often say we need to complement round pegs during the square holes. That is yet another example.
I’ve said my personal updates and you will supported they. (more…)