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How should my bank allocate costs between the construction and permanent phases when the bank discloses a construction/permanent loan as two separate transactions?

My bank discloses construction/permanent loans as two separate transactions. How should it allocate costs between the construction and permanent phases when the bank discloses a construction/permanent loan as two separate transactions?

If the creditor discloses a construction/permanent loan as two separate transactions, the creditor must allocate to the construction phase amounts for finance charges and points and fees that would not be imposed but for the construction financing. For example, inspection and handling fees for the staged disbursement of construction loan proceeds must be included in the disclosures for the construction phase and may not be included in the disclosures for the permanent phase. Fees that are not finance charges or points and fees may be allocated between the construction phase and permanent phase in any manner the creditor chooses (See Regulation Z §1026.17(c)(6) comment 5). (August 2018)

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