FHA issued Mortgagee Letter 2019-08, clarifying and revising policy with respect to the Construction to Permanent (CP) and Building on Own Land (BOOL) programs. As outlined in the Mortgagee Letter, FHA clarified distinctions in policy between each program based on financing structure (“one time close” for the CP program versus “two-step close” for the BOOL program). FHA also revised guidance pertaining to the use of the borrower’s equity in land for the purpose of satisfying the borrower’s “minimum required investment” in both programs. The clarifications and revisions apply to mortgages with case numbers assigned on or after June 17, 2019 (lenders may, however, implement the clarification and revisions immediately).
State Compliance Summary
Tennessee Increases Permissible Interest Rate for Closed-end Loans under Industrial Loan and Thrift Companies Act
Tennessee passed a bill increasing the permissible interest rate for closed-end loans under the Industrial Loan and Thrift Companies Act (ILTCA). Under the bill, the
April 1, 2025
