At your seminar on the Integrated Mortgage Disclosures you said that begining in August of 2015 Temporary construction loans will need the GFE and early disclosures. Presently, if we have a committment letter from another lending institution we do not give the GFE and early disclosures, that being said; do we continue to do as we are currently doing? Regardless, will be be required to provide the GFE and early disclosures on all temporary construction loans?
You can continue your current practice until August 1, 2015. On August 1, 2015 construction-only loans will fall within the scope of the integrated disclosure rules and you will need to give the integrated disclosure on those loans.