Q: Is this loan reportable: a 12-month construction loan that must be refinanced at the end of the 12-month period? (The loan does not include an option for rolling into permanent financing.)
A: Based on the Federal Financial Institutions Examination Council's (FFIEC) HMDA Frequently Asked Questions (HMDA FAQs),1 a primary consideration for determining if a loan is temporary financing is whether it will be replaced by permanent financing of a much longer term. Therefore, if this loan will likely be replaced by permanent financing by the bank or another lender, even if the loan does not include a permanent financing rollover option, it would likely be considered temporary financing and therefore exempt from HMDA reporting.
This can be found in - HMDA FAQ#3 of the FAQs. The Federal Reserve Board FAQs can be found at: https://consumercomplianceoutlook.org/2011/second-quarter/hmda-and-cra-data-reporting/