No. In the scenario described, part of the loan will be used for purchasing a dwelling in addition to constructing a dwelling for sale. Therefore, the transaction described above is not excluded from HMDA and should be reported as a home purchase loan. A construction-only loan or line of credit is considered temporary financing and excluded from collection and reporting requirements under comment 3(c)(3)-2
if the loan or line of credit is extended to a person exclusively to construct a dwelling for sale
. Comment 3(c)(3)-2
to Regulation C, 12 CFR § 1003.3(c)(3).
This Q&A was based on information contained in the Consumer Financial Protection Bureau’s HMDA FAQs Compliance Aid, which may be updated from time to time. This HMDA-related issuance may be found here: